# A Report By Enviros Consulting Limited: February 2009 Office Of Rail Regulation Sustainability Benchmarking Final Report

Publication title 
Office of Rail Regulation Sustainability Benchmarking Report 
CAN 
OF0080006 
Volume number 
Volume 1 of 1 
Version 
Final Report 
Date 
FEBRUARY 2009 
File Reference 
ORR Benchmarking Report  

 Prepared by: Rachel Kerlir,               Lucy Chesterfield,       Michael Samways, Project manager Reviewed by: 

## Rachel Pickering, Project Director

 
Client Address:  
                                                     Office of Rail Regulation 
                                                     One Kemble Street 
                                                     London 
                                                     WC2B 4AN 
 
Enviros Contact Details:  
                                                     Enviros Consulting Ltd 
                                                     20-23 Greville Street 
                                                     Farringdon 
                                                     London 
                                                     BT6 8DN 
                                                      

 

1. 
INTRODUCTION 
1 
1.1 
Background 
1 
1.2 
Key Developments since the 2006 Study 
2 
2. 
METHODOLOGY 
4 
2.1 
General Approach and Methodology 
4 
2.2 
Benchmarking Frameworks 
4 
2.3 
Application of Company Information 
5 
2.4 
The Standards Used 
5 
3. 
RESULTS & RECOMMENDATIONS 
7 
3.1 
Summary Framework 
7 
3.2 
Detailed Analysis of ORR's Performance and Recommendations 
9 
3.3 
Conclusions 
23 
4. 
REFERENCES 
25 APPENDICES 

## 1. Benchmarking Frameworks 2. Summary Of Regulators Duties 1. Introduction

1.1 
Background We have worked with the Office of Rail Regulation (ORR) since 2006, providing 
expert advice on developing the ORR sustainable development policy. This work 
involved undertaking a benchmarking study, a review of documents developed to 
consult the rail industry on the SD policy proposals, an evaluation of the consultation responses and expert advice on the draft conclusions. 
 
In conducting its operations, the Office of Rail Regulation has a number of duties, 
including: ♦ 
To contribute to the achievement of sustainable development;  
♦ 
To have regard to the effect on the environment of activities connected with the 
provision of rail services; and 
♦ 
To have regard to the purpose of conserving biodiversity. These duties have to be balanced alongside other statutory duties including: ♦ 
To ensure that Network Rail manages the network effectively; 
♦ 
To develop policy, ensure regulatory compliance, and encourage improved performance 
in health and safety; and 
♦ 
To license operators of railway assets, set access terms to the network and other 
railway facilities, and enforce competition law in the rail sector. 
 
In April 2007, ORR published its sustainable development conclusions and policy statement. The Sustainable Development Policy explains how ORR is going to discharge its SD duties by using its regulatory powers and influence to work to develop a more sustainable railway as part of a sustainable transport system. In practice (and recognised in the policy) this means implementing procedures to ensure 
consideration of the environmental, social and economic effect of delivering the rail industry's activities alongside other duties. Since the policy was published, ORR has primarily focused on environmental initiatives as that was the weakest area in which ORR considered it could add most value. ORR also has a key role in ensuring that the railway industry better understand its performance in terms of sustainable development by effectively measuring and improving it and by sharing information and best practice and by introducing new 
targets and incentives to promote sustainable development. Following on from the published SD policy and in light of the previous benchmarking study completed in 2006, ORR commissioned Enviros to complete a further benchmarking exercise to evaluate improvements achieved in light of this policy. The benchmarking study aims were to: ♦ 
Indicate to what extent ORR has implemented measures which meet its sustainability 
duties, as far as possible in comparison with other relevant  organisations; 
♦ 
Identify key elements of good practice in relation to SD and the role of organisations 
such as those benchmarked; and 
♦ 
Make recommendations on how ORR could further implement good practice in order to 
meet its SD duties. 
Enviros has conducted the benchmarking exercise involving comparison with the following organisations: 
Civil Aviation Authority (CAA) Maritime and Coastguard Agency (MCA) OFWAT OFGEM International Union of Railways (UIC) International Union of Public Transport (UITP) Federal Railroad Administration (FRA) 
These organisations were chosen as having similarities to ORR through their regulatory and/or influencing roles on 'industry sectors' including rail and other forms of transport, both in the UK and overseas.   The methodology employed for the benchmarking study is set out in more detail in the following chapter.   

## 1.2 Key Developments Since The 2006 Study

 
ORR 
 
Since the 2006 benchmarking study, ORR has revised and republished the 
Environmental Policy Guidance for license holders (reference n15) including a set 
of required environmental KPIs agreed with the rail industry.  ORR has also 
published its Sustainable Development & Environmental Duties report (reference 
n17), including sustainable development objectives, the sustainable development 
policy statement and ORR's proposals for delivering this policy.  
 
In July 2008, in the National Rail Trends publication (reference n16), ORR reported 
on the performance of the rail industry in terms of traction energy consumption and 
carbon emissions from traction.  Some additional data, such as traction energy 
efficiency and carbon intensity of rail operations, will be available later in 2009. 
Additional environmental indicators covering noise, non-traction energy use, waste 
and water, have been proposed for potential reporting to ORR.  
 
Cross industry 
 
The cross-industry Sustainable Development Steering Group (SDSG), comprising 
industry 
                  and 
                            Government 
                                                      executives 
                                                                            supported 
                                                                                                  by 
                                                                                                          the 
                                                                                                                    Rail 
                                                                                                                               Sustainable 
Development Group (RSDG), has been established. Its members include executive 
director-level representation from Network Rail, train operating companies, the Rail 
Safety and Standards Board, the Association of Train Operating Companies 
(ATOC), the Department for Transport (DfT) and the Office of Rail Regulation 
(ORR). 
 
The first sustainable development review of the mainline railways of Great Britain 
has been established by the SDSG, The case for rail 2007 (reference 81). This 
document explores sustainability in the context of rail, summarises the current 
sustainability 
                          performance 
                                                     and 
                                                               illustrates 
                                                                                    the 
                                                                                              industry's 
                                                                                                                   response 
                                                                                                                                       to 
                                                                                                                                              the 
sustainability challenges and opportunities. This includes the Sustainable Rail 
Programme (SRP) established to support the industry in reaching its full potential. 

The SRP focuses on areas where collaboration across the industry or with 
government is required to address issues or take initiatives forward.  In the SRP, a 
long term strategy - 30-year plan - has been developed.  
 
The RSDG/ RSSB ,with involvement and support from ORR, also undertook 
scenario modelling work which was published in December 2007, "SRP: Foresight 
studies in Sustainable Development - Strategic implications". The work identified 
the main drivers of change and gave an overview of the future scenarios which emerged 
through analysis and exploration of the drivers.  
 
Recently, in January 2009, the SDSG also agreed the Sustainable Development 
Principles, part of the Sustainable Rail Programme. These principles have been 
created to inform and become an integral part of the industry's culture and decision 
making processes taking account of whole system and whole life cycle approaches.   
 
The next steps in moving forward with the creation of the sustainable development 
strategy are: 
♦ 
   Rail Sustainable Development Group (RSDG) to review, modify where necessary, and 
   agree the proposed route map. 
♦ 
   RSDG to agree which people/organisations will carry out each of the tasks identified in 
   the route map, and who else is involved. 
♦ 
   Create a programme plan, 
♦ 
   Work streams to be taken forward in parallel by the most appropriate party for each, 
   guided by RSDG 
 
Many Research Programmes around sustainable development and energy 
efficiency have been carried out by Rail Safety Standards Board; many of which 
have involved the ORR. 
 
Government 

In July 2007, the UK Government issued a White Paper entitled "Delivering a 
Sustainable Railway". This paper acknowledges the achievements to date, and 
challenges ahead, for the railway industry and sets out ORR role and 
responsibilities. It takes a view on the performance of rail and sets out plans for 
growth and development to unlock the potential of rail as a "green" transport choice 
for the public.  

A further paper was issued by DfT in October 2007, "Towards a Sustainable 
Transport System (TaSTS): Supporting Economic Growth in a Low Carbon World". 
This outlines transport-related investment and policy plans with the aim of ensuring 
that the UK transport system is well-placed to play its part in the fight against 
climate change. The DfT is currently consulting on 'Delivering a Sustainable 
Transport System'  which sets out the action plan to deliver the TaSTS in the short, 
medium and long-term.   

ORR needs to ensure that its role and responsibilities in the rail industry and any 
Sustainable Development strategy, objectives, plans and policy planned or 
implemented, are in accordance with the Sustainable Rail Programme and the 
different White Papers above. 

These developments and publications have been taken into consideration in 
conducting the revised benchmarking study.   

 

## 2. Methodology 2.1 General Approach And Methodology

In an initial meeting with ORR, it was agreed that the same methodology and report format for the previous benchmarking study would be used for the revised work. This would ensure consistency and allow meaningful comparisons to be made.  
To establish the benchmarking organisations progression in terms of sustainable development, Enviros reviewed the measures implemented by each organisation since the last benchmarking report. A 'traffic light' scoring system (green, orange, red) has been used to demonstrate the level of formal measures in place and the clarity of the information that the organisation provides. To measure and map the improvements since the 2006 benchmarking study, we also set a "star code" with '**' representing a significant improvement, '*' progression and '0' no progression. Examples:  

- 
ORR has made significant progress in terms of Sustainable Development 
Policy since the previous benchmarking report, this is therefore coded as ** and the case will be highlighted green (previously it was orange). 
- 
CAA already had very comprehensive measures in place in terms of Climate 
Change and Energy in the previous analysis (denoted green), but, they have also added some improvements; therefore this key CAA area will still be 
denoted green with one star to represent the improvements.   
As OFGEM was not included in the previous benchmarking exercise, we were unable to measure its improvement.   

## 2.2 Benchmarking Frameworks

As agreed during the initial meeting, Enviros reviewed the benchmarking organisations' duties in order to redefine and agree the organisations to use in this benchmarking study - see Summary of Regulators Duties in Appendix' 2. The same organisations have been benchmarked, except that OFSTED has been replaced with OFGEM as it has greater relevance to ORR. As for the previous analysis, the benchmarking was conducted using a series of frameworks developed for the task.  Each framework was prepared by extracting appropriate elements from existing 'standards' to create sets of criteria against which benchmarking could be carried out.  The selected standards were as follows (further explanation of each is provided later): 

¡ 
UK SD Strategy Guiding Principles (subsequently not used - see below); 
¡ 
UK SD Strategy Priorities; 
¡ 
Sustainability Appraisal of Regional Spatial Strategies - Guidance; and 
¡ 
BS 8900:2005 'Guidance for Managing Sustainable Development'. 

## 2.3 Application Of Company Information

In the case of the seven external organisations, the information used to complete the benchmarking was taken from publicly available sources.  In the main part, these included annual reports and web-based material - in those versions currently available at the time of benchmarking.  The quantity and quality of information varied considerably between organisations. However each had at least a comprehensive website which included specific information on their role and key activities.  From these sources it was possible to identify -  

1. Specific SD related measures, and/or 2. Activities which, whilst not necessarily focused on SD, have a relevant impact 
(for example, operational efficiency measures which by their nature will result in 
reduced resource use). 
Benchmarking was conducted by working through the frameworks for each organisation in turn, where possible entering a summary of current activities against each criterion, as far as could be determined from the available information.   
In the case of ORR, as well as publicly available information Enviros was provided with a range of documents along with details provided in response to specific requests.  For this reason it was assumed that a lack of available information on any particular subject indicated that there was no activity in this area (however, it is accepted that discussion of the outcomes of this project may bring to light previously unrecognised activity).  Chapter 4 of this report lists the sources of information which were used in completing the benchmarking exercise.   

## 2.4 The Standards Used

The following is a description of each standard used in the benchmarking, along with a rationale for its selection. As agreed with ORR, these standards are similar to the previous ones as no significant new policy or standard has been established since the last assessment.  

## 2.4.1 Uk Sd Strategy Guiding Principles/Priorities

In 2005, the Government published 'Securing the Future' - the UK sustainable development strategy.  This sets out the agenda for achieving sustainable development (SD) across the UK and includes five guiding principles and four priorities for National action.  ORR has accepted the Strategy's definition of SD and for this reason the principles and priorities were chosen as elements in the benchmarking process. The guiding principles are presented in the Strategy as conceptual statements, whilst the priorities are presented in the form of actions at a largely national level, along with potential indicators of performance.  Because of their general nature, there are limitations in the use of the principles and priorities as criteria for assessing organisational SD activity.  This is particularly so in the case of the guiding principles, and because of the difficulty in linking specific organisational actions with particular principles these were excluded from the final frameworks.  In the case of the priorities, however, as far as possible relevant measures were identified from each organisation which could be considered relevant to particular criteria within the framework. 

## 2.4.2 Sustainability Appraisal Of Regional Spatial Strategies - Guidance

In 2005, the UK Government published guidance to assist regional and local planning bodies in carrying out sustainability appraisal (SA) of strategies and development plans, in order to meet the requirements of the European Strategic Environmental Assessment Directive.  Whilst obviously not written for this purpose, aspects of the guidance can be considered relevant when examining the outwardfacing role of regulatory bodies (such as policy making, industry guidance etc).  In particular, the headline SA objectives outlined in the guidance were adapted to produce a framework covering a wide range of SD-related issues.   

## 2.4.3 Bs 8900:2005

BS 8900:2005 'Guidance for Managing Sustainable Development' has been developed by BSi British Standards to provide guidance on managing SD to enhance organisational performance and effectiveness.  This is the first UK standard outlining how organisations should approach internal sustainability management. A framework was prepared based on Section 4 of the standard: 'Putting Sustainable Development into Practice' which includes particular actions against which benchmarking can be conducted.  It was agreed with ORR that corporate SD activity should not be a major element in the benchmarking, however the framework was used to take a brief look at what internal management measures are currently in place in ORR alongside CAA and MCA (as comparable UK organisations in contrasting industry sectors) - particularly with respect to the issue of leading by example. 

 

## 3. Results & Recommendations

The detailed results of the benchmarking against each framework are provided in Appendix 1. 

## 3.1 Summary Framework

The key results from each framework were combined to produce a summary framework, shown in table 1, overleaf. 

 

|                                                                                                        |     |     |       |       |     | Key Area   | Summary of Best Practice   |
|--------------------------------------------------------------------------------------------------------|-----|-----|-------|-------|-----|------------|----------------------------|
| ORR                                                                                                    | CAA | MCA | OFWAT | OFGEM | UIC | UIPT       | FRA                        |
| Sustainable Development Policy                                                                         |     |     |       |       |     |            |                            |
| - Published policy statement on SD role/aims                                                           |     |     |       |       |     |            |                            |
| - Strategy for fulfilling SD role defined                                                              |     |     |       |       |     |            |                            |
| **                                                                                                     | *   | *   | **    |       |     |            |                            |
| o                                                                                                      | o   | o   |       |       |     |            |                            |
| Climate Change and Energy                                                                              |     |     |       |       |     |            |                            |
| - Regulatory/advisory measures in place to ensure reduction in energy use/greenhouse gas emissions     |     |     |       |       |     |            |                            |
| **                                                                                                     | *   | *   | **    | *     | *   |            |                            |
| o                                                                                                      |     |     |       |       |     |            |                            |
| Environmental Management                                                                               |     |     |       |       |     |            |                            |
| - Regulatory/advisory measures in place to ensure prevention/correction of environmental damage        |     |     |       |       |     |            |                            |
| - Advisory measures in place to encourage EMS implementation                                           |     |     |       |       |     |            |                            |
| **                                                                                                     | *   | *   |       |       |     |            |                            |
| o                                                                                                      |     |     |       |       |     |            |                            |
| o                                                                                                      | o   | o   |       |       |     |            |                            |
| Health & Safety Management                                                                             |     |     |       |       |     |            |                            |
| - Regulatory/advisory measures in place to ensure high health & safety standards (industry and public) |     |     |       |       |     |            |                            |
| - Advisory measures in place to encourage H&SMS implementation                                         |     |     |       |       |     |            |                            |
| **                                                                                                     | *   | *   | *     | *     |     |            |                            |
| o                                                                                                      |     |     |       |       |     |            |                            |
| *                                                                                                      |     |     |       |       |     |            |                            |
| - Establishment of appropriate indicators of industry SD performance                                   |     |     |       |       |     |            |                            |
| - Reporting of industry SD performance                                                                 |     |     |       |       |     |            |                            |
| *                                                                                                      |     |     |       |       |     |            |                            |
| o                                                                                                      | o   | o   | o     | o     |     |            |                            |
| *                                                                                                      |     |     |       |       |     |            |                            |
| Performance Measurement and                                                                            |     |     |       |       |     |            |                            |
| Reporting                                                                                              |     |     |       |       |     |            |                            |
Social Impact
 - Regulatory/advisory measures to ensure effective management of social issues (incl diversity, access, crime)
and ethical commercial and operating practices
*
Sustainable Economic Development
 - Regulatory/advisory measures in place to ensure efficiency - Regulatory/advisory measures in place to ensure fair commercial practices and competition - Financial incentive/disincentive mechanisms to ensure sustainable operational practices
*
o
o
o
o
Sustainable Development Research
 - Conducting research to improve industry sustainability (incl appropriate technology) - Encouraging/supporting relevant research by external bodies (incl universities)
*
o
*
o
Leading by Example
 - Internal measures in place which demonstrate best practice, setting a good example to industry (incl policy, management measures, performance reporting in relation to SD)
*
*
o
*
o
 = Comprehensive, formal measures in place which are specific to this key area = Limited range of formal measures in place, including measures which have relevance but are not specific to this key area = Few or no formal measures identified (from information available)
Significant improvement Improvement No change or very limited

In order to produce this framework, nine key areas were identified which could be considered as summarising best practice taking into account which SD measures organisations such as ORR (i.e. bodies with a remit to regulate/influence/represent particular sectors, and in particular transport) could be expected to implement given the nature and scope of their roles. The following section aims to:  

¡ 
Provide examples of best practice in each of the nine key areas (above), and outline ORR's performance; 
¡ 
Measure the improvements compared to the 2006 benchmarking report within ORR and make recommendations on measures ORR should implement as part of a future SD strategy; and 
¡ 
Cross reference the above with the key elements of the UK SD Strategy. 

## 3.2 Detailed Analysis Of Orr'S Performance And Recommendations 3.2.1 Sustainable Development Policy

Within 
         the 
               benchmarked 
                               organisations, 
                                                improvements 
                                                                 around 
                                                                           sustainable 
development policy can be observed either at an internal or an external level. 
However, only half of the benchmarked organisations have a formal Sustainability or 
Environmental Policy in place in order to bring and motivate continual improvement 
of the sustainability performance in their related industry.  

Some policies are more focused on the environmental aspects of sustainability and 
others more broadly cover all the dimensions of sustainable development. These 
policies are named "Environmental Policy", or "Sustainable Development Policy", but 
generally, the policy title does not correspond directly to their content. A specific 
example is the OFWAT Climate Change Policy Statement which, despite its name, 
includes environmental, social and economical aspects. 

Since the last benchmarking study, various consultation exercises have been carried 
out around sustainable development policy; as an example, one of OFWAT's 
consultations set out a tentative proposal for a series of criteria or questions that 
they might use to assess policies against sustainable development principles.  

Examples of Best Practice 
 
Publication of a sustainable development or/and environmental policy such as 
Sustainable Development and Aviation Environmental Policy or Environmental Policy 
Committee (CAA) 

Environmental Policy Guidance for license holders (ORR) 

Establishing a Sustainable Development Policy Group - a working group to progress 
and implement SD strategy (ORR) 

Sustainable Development Operations Policy Statement (MCA) OFGEM Operations Environmental Policy Statement OFWAT's strategy - taking a forward look 

In December 2007, ORR published the Environmental Policy Guidance for license holders. This document includes the commitments, objectives and management arrangements that the policy should cover. This also sets out the KPIs to measure sustainable performance, for which the rail industry has agreed to produce accurate and verifiable data for. In the ORR's Sustainable Development & Environmental Duties report, published in April 2007, ORR provides the sustainable development objectives, a policy statement and ORR's proposals for delivering this policy. The terms of reference for the ORR Sustainable Development Policy Group have been revised to ensure a regular review of ORR's sustainable development policy with respect to its duties as defined by Section 4 of the Railways Act 1993.  The policy will be formally reviewed by the SDPG every two years, or earlier if issues impacting upon ORR's role are identified. In the last ORR SDPG meeting, it has been reported that the Environmental Advisory Group agreed that an ORR corporate environmental policy, based on Environmental Management System principles, should be drafted for presentation to the group for discussion. No details were provided about policy content or timeline. 

ORR performed quite well compared to the other organisations with an Environmental Guidance Policy and a Sustainable Development Policy Statement. Consideration could be given to how sustainable procurement issues could be further influenced. ORR should plan to establish an internal environmental and sustainability policy in order to demonstrate that internally ORR's operations are carried out in accordance with SD principles.  This could relate to resource efficiency of energy, water, paper and other consumables in the ORR offices together with a policy statement relating to travel etc.      

This key area relates to all elements of the Strategy, rather than any particular principal or priority. 

## 3.2.2 Climate Change And Energy

Climate Change and Energy is now a key consideration within government targets and regulations. There have been notable improvements in this area within most of the benchmarked organisations. There are however different levels of involvement and measures in place. Some of the regulators, such MCA, CAA and OFGEM have set some internal targets for reducing energy or utilities consumption. More specifically, CAA monitors energy use and reports data annually comparing to their initial targets.  Last year CAA 
reported a reduction of energy use within their offices. Other regulators, such as ORR, OFWAT or UITP, developed guidance, best practice examples or published some KPIs in order to encourage the whole industry to reduce carbon emissions and energy use. 

As an example, OFWAT, in its Climate Change Policy Statement provides some recommendations and measures to implement the current achievements and future targets for many aspects of sustainability such as carbon management, renewable energy, competition and innovation, etc to the water industry. 

OFGEM has proposed reforms that would provide financial incentives for electricity 
transmission companies to expand capacity ahead of demand from new generation 
sources; it would facilitate connection to renewable and other low-carbon energy 
sources. 
          This 
                reform 
                         is 
                            intended 
                                       to 
                                           help 
                                                 spread 
                                                          the 
                                                               energy 
                                                                        renewable 
implementation in the UK. 

A particular tool that UIC has developed which encourages public engagement is 
'Eco Passenger' and 'Eco Transit'. These internet tools calculate and show in detail 
to every customer the energy consumption, CO2 emissions and local pollutants for 
each selected route.  

## Examples Of Best Practice Development Of Performance Monitoring

Research into energy efficiency technologies, cleaner diesel and renewable energy sources Ongoing work on the EU Emissions Trading Scheme (OFGEM) A review of the Energy Efficiency Commitment 2005-2008 (OFGEM) Internal targets - Climate Change and Energy - in the Sustainable Development Action Plan (SDAP), June 2008, (OFGEM) 

## Carbon Reduction Working Group - Crwg (Orr)

Climate Change and CO2 emissions & Energy Efficiency chapters of the Railway and Environment, EU facts and figures report, presenting statistical and factual evidence on the impact of the different transport modes (UIC with the Community of European Railway and Infrastructure Companies). Developing metrics and benchmarking for sustainable development in the rail industry, November 2007 - Environmental metrics related to climate change and energy (RSSB). 

## Improving Rail'S Energy Efficiency (Rssb)

SD principles - Carbon Smart and Energy Wise Principles (Sustainable Rail Programme) 

The Rail Sustainable Development Group has selected 11 metrics from the 50 sustainability performance metrics of the "Developing metrics and benchmarking for sustainable development in the rail industry" report (Nov 07), to be monitored in future; it is stated that the 8 environmental metrics need to be reported to ORR. Most of the environmental metrics are related to climate change and energy. In December 2007, ORR published its Environmental Guidance Policy and some associated KPIs to measure and report sustainable performance in the rail industry. 

In July 2008, ORR published their first environmental indicators in the National Rail Trends - Sustainable Development - reporting on traction energy consumption and related carbon dioxide emissions. As mentioned in Chapter 1 (1.2), some additional indicators, such as traction energy efficiency and carbon intensity of rail operations, will be available later this year as their associated KPIs have been required by ORR for the second half of 2008. ORR supported the establishment of the Sustainable Rail Programme' SD principles which aim to achieve long term reductions in carbon emissions through improved energy efficiency, new technology and lower carbon power sources and facilitate modal shift, helping others make more carbon efficient journeys. The SD principles have been agreed by the SDSG in January 2009. 

As stated in the last Carbon Reduction Working Group, ORR continues to facilitate the promotion of energy efficiency. 

Recommended Measures 
 
ORR published some data around the KPIs of traction energy consumption and 
carbon emissions from traction and will be able to publish data against further 
environmental indicators this year. Therefore, ORR could establish an individual 
environmental performance review, not part of the National Rail Trends report. 

All environmental metrics selected by RSSB - to be reported to ORR - need to be 
included in the ORR Environmental Policy Guidance and reported in the ORR 
annual environmental indicators reporting.  

As suggested in the last Carbon Reduction Working Group, ORR could support and 
lead the creation of a cross industry metering steering group. 
 
ORR could set some specific improvement targets to be achieved by the rail 
industry to help minimise the climate change impact of the rail industry.  These 
targets could be provided in a broader ORR Sustainable Development Strategy with 
specific Climate Change and Energy Actions Plans for the rail industry; that might 
also include the establishment and publication of a Toolkit for reducing carbon 
emissions from transport. 
 
ORR could also gather and publish best practice examples looking at other 
European regulators performance in the rail industry.  

Generally, more work could be established internally and for the rail industry within 
the fields of Energy Efficiency Technology, Climate change, Carbon emissions etc: 
- more information could be published (e.g. leaflet or Information sheet) 
- Specific working groups could be created such as a Energy Efficiency 
  Technology working group 
- Deeper considerations of financial measures implementation could be taken 
  such as environmental charging and incentives in order to penalise/ reward 
  energy related performance including the rate of uptake of efficient technology 
 
As stated in the previous benchmarking report, ORR should consider their internal 
impact on energy and climate change and look to collect data in this area to 
understand their current impact and consider improvements which could be made 
to reduce energy consumption internally. 

This key area relates to 'Climate Change and Energy'. 

## 3.2.3 Environmental Management

The importance of preserving the environment has intensified over the last few years and consequently so have regulators duties to ensure prevention/correction of environmental damage. There has therefore been a significant improvement amongst the majority of the benchmarked organisations in terms of available environmental guidance and advisory measures. In comparison to the other benchmarked organisations included in this study, OFWAT was found to have limited environmental information; as such there has been no significant improvement identified from the previous benchmarking exercise. UIPT also has limited information on environmental damage and therefore there also appears to be limited progress from the previous benchmarking study. 

Environmental Research and Consultancy Department provides environmental advice and information (CAA) Environmental Information Sheets (in various forms for operator and in some cases the public e.g. CAA in relation to noise) (CAA). Quality Assurance Branch - Auditing both to ISO and ISM standards (MCA). Environmental Management System certified to the ISO 14001 standard (OFGEM).  

ORR has a statutory role to have regard to the effect on the environment of activities connected with the provision of rail services. ORR has updated the document 'Railway Operations and the Environment - Environmental Guidance'. 

The guidance provides advice on issues that each enterprise should address in its environmental policies and practices and includes guidance on policy, objectives and management arrangements.  The new guidance includes, for the first time, a requirement to contribute to industry-wide reporting against a number of environmental performance indicators. These indicators have been developed by the industry. ORR monitors the environmental performance of the industry against the indicators and the results are published annually in ORR national rail trends. Tracking the indicators over time will bring the improving performance and environmental benefits of railway services to a wider audience, whilst encouraging the industry to improve its performance year by year.      

ORR's position in terms of environmental management has improved significantly from the previous benchmarking study in 2006. ORR already has measures in place to assist prevention/correction of environmental damage. 

The previous benchmarking report recommended that specific guidance could be 
developed 
           for 
                operators/inspectors 
                                     in 
                                          specific 
                                                   areas, 
                                                           including 
                                                                      energy 
use/vibration, visual intrusion. These recommendations haven't been implemented 
and have therefore been repeated as a recommended measure.  

ORR should consider providing further guidance to licence holders in terms of Environmental Management Systems and encourage licence holders to develop an ISO 14001 accredited systems to demonstrate internal commitment to SD and environmental improvements. ORR should also consider developing this also, internally.  

This area relates to the priorities 'Climate Change and Energy' and 'Natural Resource Protection and Environmental Enhancement'.  

## 3.2.4 Health & Safety Management

'Improving Health and Safety performance' is an important objective for all of the benchmarked organisations. There has been some notable progress in terms of their health and safety management since the 2006 study. A small number of examples of improvements are listed below. CAA, has made progress in a range of areas, but health and safety reporting and publicly available safety information were noted improvements. MCA statistics and accident reports showed a substantial increase in the number of workplace related accidents. In response to this the MCA made a commitment to issue more information in the form of posters, leaflets and booklets on occupational Health and Safety. This is one example of good practice that MCA has demonstrated improvement in. FRA has made significant progress, one example being the launch of a new web site. This was established for the purpose of making railroad safety information readily available to a broad constituency.    

Aviation Occupation Health and Safety Steering Group (CAA)  
General Aviation Safety Awards (CAA) Safety Management Systems (CAA) Safety Platform Groups - Human Factors Working Group, Occupational Health and Safety Group, Safety database development (UIC)  
Theme-based groups -Border crossings, building on the work of the SchenegenRail group, Security of international freight corridors, Terrorism including institutional relations (UIC).   
Railroad Safety Advisory Committee (FRA) National Rail Safety Action Plan (FRA) European Road Safety Charter (UITP) Railway Industry Advisory Committee (ORR) 
Health and Safety Policy Group (ORR) 
Railway Safety and Statistical Report (2007) - The Safety and Economic Regulator of Britain's railways (ORR) Promoting Safety and Value in Britain's Railways: ORR Strategy for 2009-2014 (ORR) Federal Railroad Administration Railroad Safety Advisory Committee (FRA)  

Excellence in health and safety culture and risk control is an important goal for ORR and there are a wide range of measures in place to achieve this goal. These measures have improved significantly since 2006, particularly in terms of reporting and strategies to achieve improved safety performance. Other measures which ensure high standards of health and safety include inspections and audits to check that rail industry has the management systems in place effectively controlling health and safety risks. The goal to introduce a process of systematic audit and inspection of duty holders' management systems, incident investigations and action tracking processes is a new approach for ORR and is expected to have significant benefit for the industry. Provision of site and written advice and guidance on how to comply with the law is another positive measure. A Health and Safety Policy Group was established in July 2008. The objective of this group is to ensure that emerging and existing health and safety policy issues are: identified; discussed; prioritised; communicated; and resolved. 

 

Further emphasis could be placed on increasing regulatory action so that all duty holders implement good practice. To track progress a more systematic audit system should be put in place. The previous benchmarking report recommended that the area of health and safety should be recognised and promoted as a key aspect of ORR's SD Duties and is incorporated into future SD Policy and strategy. In ORR Sustainable development policy statement published in 2007, there is no reference to Health and Safety.  
Enviros recommends that health and safety is recognised as a key aspect when updating the sustainable development policy. Employee safety was demonstrated as one area of weakness in the ORR Annual Report. Improvements could be made by increasing awareness through further training and information leaflets.  

This key area related to the priority 'Sustainable Communities'. 

## 3.2.5 Performance Measurement And Reporting

Organisations are required to publish an increasing amount of information due to regulations such as the Freedom of Information Act. Due to such legislation organisations are tending to report and measure against a greater number of indicators.  
The majority of the benchmarked organisations have made progress in performance and reporting, however much of the performance measurement is still focused around health and safety. 

The case for Rail 2007 (SDSG) Development of measurement and reporting framework for H&S (ORR) The Mandatory Occurrence Reporting (MOR) Scheme (CAA) Monitoring and reporting of SD related performance by operators (ORR) Reporting against safety indicators (ORR) Monitoring of the allowance market's development and OFGEM annual monitoring supplier performance (OFGEM)  

ORR produces a large number of publications throughout the year. These include  
fact sheets on environmental, health and safety and other SD issues. However 
detailed reporting is focused mainly around health and safety including the Railway 
Safety Statistical Report.  
 
ORR's April 2007 policy document indicated that it would work with the industry to 
develop a limited number of KPIs, the data for which should be produced, verified 
and owned by the rail industry to provide credibility. Following on from this, the 
RSSB, on behalf of the industry, agreed in December 2007 on a range of KPIs that 
ORR should publish. The first of these, initially published in July 2008, related to: 
  

¡ 
Total traction energy consumption (aggregated) and  
¡ 
Total carbon dioxide emissions from traction energy (aggregated)  
 
The industry has also committed to publish of the following KPIs, and ORR will be working with the industry to develop the methodology for data collection and development: 
 
¡ 
Traction energy efficiency and carbon intensity indicators 
¡ 
Air emissions  
¡ 
Noise impact 
¡ 
Non traction energy consumption  
¡ 
Non traction carbon intensity 
¡ 
Waste material generation  
¡ 
Water consumption  
This demonstrates significant improvement and commitment towards environmental monitoring and reporting. In addition ORR has developed a number of environmental monitoring measures (energy efficiency and CO2 emissions, Sites of Special Scientific Interest, environmental incidents, reduce/reuse/recycle initiatives) against which Network Rail will be measured and held to account during Control Periodic Review 4. These form part of a wider monitoring framework developed by ORR addressing all of its periodic review activities. Further to this ORR has reviewed the level of information previously provided by Network Rail on its environmental activities and proposed to and agreed with Network Rail the level of information that it will provide both in its future business plans and its associated annual returns. For example, the business plan, must describe specific objectives and targets to improve Network Rail's environmental performance with regards to "Improving energy efficiency and reducing emissions and achieving sustainable consumption". Evaluation of performance during 2008- 2009 will focus on improving energy efficiency, achieving sustainable consumption and protecting the natural environment. ORR has also adopted a Publication Scheme, this sets out the information ORR 
intends to publish as a matter of routine. This scheme ensures that information is available, without the need to make general information requests. 

Although improvements have been made in terms of environmental reporting, ORR still predominately reports on Health and Safety. ORR should focus on improving environmental reporting to the same standards as Health and Safety Reporting. ORR should continue to influence the rail industry SD performance by developing further methods to measure operators' performance by, for example, setting targets related to the environmental KPIs.  
ORR currently has relatively limited measures in place to report social and community issues. Although this is deemed to be outside of ORR's statutory remit, further consideration should be given to how ORR can influence this core pillar of sustainable development.  An initial step could be to provide factsheets to rail operators highlighting best practice in this area.    

This key area relates to all elements of the strategy with regard to the aspects of SD which should be measured and reported, and specifically to 'Sustainable Communities' with regard to public participation.  

## 3.2.6 Social Impact

Social impact has become an increasingly important indicator for sustainable development. Regulators have therefore begun to incorporate social issues, such as public engagement, public advice and diversity into their operating strategies.  
CAA has recently introduced a Disability Equality Scheme 2008-2011. The DES sets out a commitment to disabled people and approach to addressing disability equality.  
MCA has improved significantly in terms of public engagement and now provides a greater amount of educational material, such as 'don't drink and drown leaflet', interactive information packs e.g. 'Mayday pack' and 'Library Story telling'. The measures have been put in place to encourage a sense of community and raise sustainable development awareness. OFWAT has made progress in terms of its social impacts. Areas of particular best practice include sustainable employment practices such as flexible working and customer value. Achieving a strong, healthy and just society was also identified as a key action for 2007-2008.   
A particular tool that UIC has developed which encourages public engagement is 
'Eco Passenger' and 'Eco Transit'. These internet tools calculate and show in detail to every customer the energy consumption, CO2 emissions and local pollutants for each selected route.  

Environmental Information Sheets - e.g. Fuel dumping and Contrails and Aircraft noise (CAA). 'Travelling safely' and Icefalls leaflet 'Version 3' June 2007 (CAA) Disability Equality Scheme 2008 - 2011 (CAA) MCA'S Equal Opportunities Statement (MCA) Social Action Strategy 2008-2009 (OFGEM) Consumer First Programme launched to give OFGEM a clear picture of consumer attitudes and expectations (OFGEM) Consumer Awareness Programme - calculates the energy consumption, CO2 emissions and local pollutants for each selected route (OFGEM) 
ORR Training Policy, 2006 and ORR Training Sponsorship Policy (ORR) National Rail Corporate Social Responsibility Report, 2007  

ORR has made progress in terms of the regulatory and advisory measures in place to address particular areas of social impact. In particular, ORR are clearer as to their role in relation to sustainable development as demonstrated by publication of the ORR sustainable development policy. ORR is also committed internally to equal opportunities. ORR Policy aims to provide equal opportunity for employment, career development and promotion to all that are eligible on the basis of ability, qualification and availability to work.  
ORR is an investor in people and promote personal development amongst their staff. Personal Development Grants are available for staff to undertake a development activity to enhance their skills.  

ORR still currently has limited measures to address non-regulatory social impact aspects. 

ORR 
     should 
           continue 
                   to 
                      ensure 
                             sustainable 
                                       development 
                                                   awareness 
                                                            is 
communicated throughout the industry. For example, guidance to licensed 
operators could be increased and developed further. A SD- related competency 
model for application by the rail industry in training and development would develop 
this awareness also.   

ORR should also consider means for increasing public engagement on SD. This is 
something other regulators such as MCA have strength in. This would obviously 
need to be done in conjunction with Department for Transport and it may be that 
clear links to DfT public engagement docs are made through the ORR website and 
licensed operators are made aware.     

Another recommendation which was detailed in the previous benchmarking report 
which has not been developed as yet and still has significance is the scope to review 
community impact and involvement through the rail industry, for example, community 
outreach, voluntary and charitable activities and cause related marketing - i.e. 
raising awareness of both ORR's work and particular relevant charitable 
causes/issues through association with ORR's name.  

This key area relates to the priority 'Sustainable Communities'.  

## 3.2.7 Sustainable Economic Development

In terms of best practice it is difficult within the scope of this study to determine which, if any, of the benchmarked organisations constitute best practice. Each industry has its own unique aspects that justify, or necessitate, differences in the regulatory approach. Nonetheless, we note that employing incentive based regulation itself continues to be generally regarded as the best practice model to drive improvements in efficiency and outputs in regulated companies. The Government recognises that the polluter pays principle is key to achieving sustainable development. As stated in one of OFWAT's consultation documents, 'a sustainable outcome may require more emphasis on addressing diffuse pollution, with those responsible bearing a fair share of clean up costs'. OFWAT has published documents encouraging low-carbon investment decisions, setting price limits and on achieving a sustainable economy. OFGEM has set the "Managing the transition to a low carbon economy" as one of the key themes which captures how the Gas and Electricity Markets Authority should contribute to the sustainability challenges of the 21st century. They also issued guidance in June 2008 to code panels on the consideration and treatment of the costs of GHG emissions under the existing code objectives. This guidance sets out OFGEM's view that the economic costs of GHG emissions should be taken into account by code panels and industry participants when assessing modification proposals for industry arrangements.  
In terms of a low carbon economy, the government also published "Towards a Sustainable Transport System, Supporting Economic Growth in a Low Carbon World" 
in October 2007. 

ORR has, over the last three and a half years, undertaken their periodic review of Network Rail's outputs and track and station access charges. Following this, Network Rail has until 5 February 2009 to decide whether it accepts or rejects the conclusions of the periodic review. As a conclusion, the Network Rail, working with its industry partners, can and should deliver better outcomes at lower cost". 

ORR has undertaken an international benchmarking study, as part of its Periodic 
Review in 2008 to inform ORR's judgements on efficiency, for example: ♦ 
Total maintenance and renewals  
♦ 
Signalling and possessions and  
♦ 
Asset management  
This is a significant piece of work that will drive greater efficiencies within the rail industry in the next 5 years and ensure sustainable economic development within Network Rail. In future the government' plans to focus more on environmental issues and the next Periodic Review, due to be completed in 2013, is expected to include environmental targets for Network Rail. 

ORR has limited financial incentives or mechanisms to explicitly promote environmental performance. It is clearly stated in the ORR's duties report that the introduction of any new financial incentive would need to be considered very carefully. Also, in the PR08 document, "Advice to Ministers and framework for setting access charges", ORR 
confirmed that: 

- a financial incentive may be useful in the future but ideally this should only be 
introduced where all parties have a clear understanding of the KPIs that 
underpin it 
- ORR do not intend to introduce an environmental charge … 
Since ORR has undertaken some initial consultation on environmental charges, no more specific work has been established. It is understood that ORR is currently giving further thought to environmental charging and incentives and will likely consult on this specific aspect in the near future. 

ORR should further consider the use of environmental charging and, in particular, incentives for good performance and implementation of SD. ORR could develop a low carbon rail economy approach and promote its benefits and promote ways to facilitate the development of local rail investment packages, encouraging a more strategic approach to local transport plans which could be part of the low carbon economy strategy.  

This key area relates to the priority 'Sustainable Consumption and Production. 

## 3.2.8 Sustainable Development Research

The majority of the benchmarked organisations have developed multiple research projects around safety or around specific environmental issues directly linked to their core industry. MCA has diverse ongoing research projects mainly on waste, ecological sites and ecosystems. FRA, has undertaken research and development projects both independently and in partnership with public or private organizations, including institutions of higher learning, through the provision of grant funding, cooperative agreements, memoranda of understanding, and contracts.  

 Research on specific environmental issues including renewables, port waste reception facilities, treatment and oily waste, noise impacts Diverse Research Projects in Sustainable Development such as "Review of research relating to sustainable development for the Railway (RSSB) Environmental Research and Consultancy Department (CAA) Carbon price on costs of generation (OFGEM) Three year Energy Demand Research Project (OFGEM) Five Year Strategic Plan for Railroad Research, Development and Demonstrations (FRA) 

ORR continues to support and contribute to the work being undertaken by the Rail Safety and Standards Board, both in developing the sustainable case for rail and in further research activities that could improve the future sustainability of the railway, as stated in the ORR's sustainable development and environmental duties. It is however difficult to measure the level of ORR's support and involvement within RSSB's Research Programmes, linked to Sustainable Development. 

ORR should continue to work with the RSSB and others to lead or participate in SD research projects. ORR could provide more accessible information on developing or completed research projects relevant to the rail industry through the website and by direct communication with the rail operators in order to raise awareness of available information.   

This key area relates to the priorities 'Sustainable Consumption and Production' and Sustainable Communities. 

## 3.2.9 Leading By Example

There is increasing competition between organisations who want to be seen to be leading by example. Each of the benchmarking organisations, have different approaches to achieving this. OFWAT, for example, has undertaken benchmarking work for the last ten years looking at the other international regulators in the same field and comparing activity to identify best practice.  . 

International Comparisons report 2008 (OFWAT) Environmental Advisory Group (ORR) ISO 14001 standard internally and Social Strategy (OFGEM) Commitment to establish a Sustainable development Maturity Matrix (MCA)  

ORR now has a Sustainable Development Policy in place and revised Environmental Policy Guidance for the rail industry. Internally ORR has in place a Health and Safety and Environmental policy and an Equality and Diversity policy.  
The creation of the Environmental Advisory Group (EAG) in November 2007 aims to improve ORR's internal monitoring and reporting of its environmental aspects such as energy, travel, waste and procurement. It was agreed in the last EAG meeting that ORR should develop an Environmental Management System and an Environmental Policy. 

Further structured management measures are still not apparent within ORR.  

By adopting best practice internally, ORR is in a position to lead by example and influence those operating within the rail industry. Following the previous benchmarking report, ORR has made progress in developing internal SD management. There is still however many measures which ORR could consider in order to develop its internal approach further, implementing the action mentioned in the previous paragraph. In brief, the principle activities are likely to include the following:  

♦ 
Definition 
of 
objectives 
and 
targets 
for 
improving 
performance 
and 
implementing systems across a range of SD aspects  
♦ 
Detailed programme of implementation, with defined roles and responsibilities 
♦ 
Further training and awareness raising for staff, including SD in general and 
specific areas such as energy use, waste minimisation etc.  
♦ 
Greater reporting against internal SD indicators and targets. 
ORR should consider adoption of certified systems such as ISO 14001 which have been successfully implemented in other public sector organisations.  
In addition to internal systems, ORR should consider the adoption of outward facing activities including community involvement (including staff volunteering and mentoring programmes and structured support of appropriate charities).  

This key area relates to all elements of the Strategy, rather than any particular principal or priority. 

## 3.3 Conclusions

Compared to the previous benchmarking study, it is clear that all the organisations have made some improvements in addressing sustainable development issues.  
From the publicly available information. ORR showed significant progress in 5 
categories and some improvements in 2 others. This demonstrates a real commitment to achieve and promote sustainable development principles. The following points summarise ORR's performance in the benchmarking.  
 

¡ 
Based on the information available, ORR compares well with the other organisations benchmarked and could be viewed as being on a par with most of the others in terms of the number of SD-related activities undertaken/measures 
in place.  However, other regulators such as, CAA and OFGEM, display a wider range of measures in place, with measures in all nine key areas, including such examples, as conducting a wide range of SD-related research, or providing SD- related awards for operators. 
¡ 
ORR SD focus has to date, largely been limited to health & safety, environmental issues and commercial practices. This is understandable given 
the primary function of ORR. A key area where ORR appears to have undertaken fewest activities is in terms of social impacts and should be an area 
for future consideration.  
¡ 
ORR has made great improvement in the area of Performance Measurement 
and reporting. This is mainly due to the publishing of the 'Environmental Guidance'. No specific targets related to the environmental KPIs have been set 
though, and this should be an area of improvement for ORR.  
¡ 
Significant 
improvements 
have 
been 
made 
across 
all 
benchmarked 
organisations in terms of Health and Safety. However, a weakness in this area is that the majority of the benchmarked organisations have not fully incorporated health and safety into SD strategies. ORR should incorporate health and safety into the SD strategy.  
¡ 
In terms of Environmental Management, OFGEM is leading by example in this area. Internally they have developed a management system accredited to IS0 14001 and also provide advice and guidance to their operators. ORR has 
undertaken fewer activities in this area, but is not alone in comparison to the other benchmarked organisations.  
In the Sustainable Case for Rail 2007 (RSSB), the first sustainable development review of the mainline railways of Great Britain as part of the industry's Sustainable Rail Plan, one of the stated needs is to optimise rail's contribution to a sustainable transport system. The industry recognises the importance of working together and in partnership with the Office of Rail Regulation (ORR) and the DfT.  

 
Rail has long been regarded as an environmentally friendly mode of transport, 
particularly in terms of energy efficiency and emissions. The industry is actively 
working to maintain its environmental advantage. It is now more important than 
ever 
           to 
                  highlight 
                                     reliable, 
                                                       relevant 
                                                                         information 
                                                                                                 which 
                                                                                                               demonstrates 
                                                                                                                                           rail's 
performance in sustainable development.  

ORR has an important role in continuing to demonstrate its active progress in 
influencing the improvement of sustainable development in the rail industry.   

  

## 4. References

The following sources of information were used in completing the benchmarking exercise: 
1. Office of Rail Regulation website: www.rail-reg.gov.uk 
2. Civil Aviation Authority website: www.caa.co.uk 
3. Maritime and Coastguard Agency website: www.mcga.gov.uk 
4. OFWAT website: www.ofwat.gov.uk 
5. OFGEM website: www.ofgem.gov.uk 
6. International Union of Railways website: www.uic.asso.fr 
7. International Union of Public Transport website: www.uitp.com 
8. Federal Railroad Administration website: www.fra.dot.gov  
9. ORR Training Policy, 2006 10. ORR Health, Safety and Environmental Policy, 2005 11. ORR Annual Report and Resource Accounts - The Safety and Economic Regulator of 
Britain's Railways 2007-2008 
12. ORR Railway Safety and Statistical Report  - The Safety and Economic Regulator of 
Britain's Railways  
13. ORR Staff Handbook 14. ORR Training Policy, 2006 15. ORR Railway Operations and the Environment - Environmental Guidance 
http://www.rail-reg.gov.uk/upload/pdf/29-environment96.pdf 
16. ORR, Current National Rail Trends publications, 2008 
http://www.rail-reg.gov.uk/upload/pdf/rolling-c9-environ.pdf 
17. ORR'S Sustainable Development & Environmental Duties - Conclusions, April 2007 
http://www.rail-reg.gov.uk/upload/pdf/324.pdf 
18. ORR, Guide to supporting performance and development, 2008 
19. ORR, Periodic Review, Structure of Track Access and Station Long Term Charges, 2008 20. Renewed EU Sustainable Development Strategy, EU Council, June 2006 
21. ORR, SDPG Review of the EU Sustainable Development Strategy, July 2006 22. ORR Statutory Duties 23. ORR Outline for Consultation on Sustainable Development 24. ORR Sustainable Development Policy Steering Group minutes 25. ORR, The Stations Code 26. ORR Model Station Licence, 2007 27. National Rail Review  2006-07 28. ORR Model Passenger Licence, 2007 29. ORR Promoting Safety and value in Britain's railways - Our Strategy for 2009-14  
30. ORR Environmental Policy Guidance, December 2007  
http://www.rail-reg.gov.uk/upload/pdf/348.pdf  
31. National Rail Corporate Responsibility Report 2007-2008 32. Review of the Network Rail Licence: Statutory Notice of Proposed Modifications, 2008 
33. ORR, Regulating Rail Passenger Fares - The Role of Competition Law 
34. Complaints about rail fares and Car Park Charges the role of competition low 35. ORR Periodic review 2008: Advice to Ministers and framework for setting access charges, 
February 2007 
36. ORR, Regulating Britain's railways in 2009-14: A consultation 37. ORR Carbon Reduction Working Group  minutes 38. CAA, Annual Review, 2007 39. CAA Sustainable Development and Aviation Environmental Policy 40. CAA SRG Safety Plan 2008 41. CAA Overview of Dangerous Goods Training 42. CAA Environmental Information Sheets e.g. CAA Noise 43. CAA Environmental Research and Consultancy Department, meeting notes. 44. CAA Corporate Plan 2006-2007 for 2010-2011 45. CAA Terms of Reference for the CAA Environmental Policy Committee, 2007 46. CAA, London Heathrow, Gatwick and Standsted strategic noise map reports, December 
2007.  
47. OFGEM, Corporate Social Responsibility Report, 2007 48. OFGEM, Corporate Plan for 2006-2007 for 2010-2011 49. OFGEM, Sustainable Development Report, 2007 & 2008 
50. OFGEM, Sustainable Action Plan, 2008 51. OFGEM Sustainability and Environmental Project, 2008 52. OFGEM Sustainable Development in the Gas and Electricity Sectors fact sheet, 2008 53. OFGEM Social Action Strategy update 2008-2009 54. OFGEM Carbon Emission Reduction Target 2008-2011, Supplier Guidance 55. OFGEM A review of the Energy Efficiency Commitment 2005-2008, 2008 
56. OFWAT strategy - taking a forward look, 2008 57. OFWAT Contributing to sustainable development, a consultation on Ofwat's approach, 2006 58. OFWAT Preparing for the future - Ofwat's climate change policy statement, 2008. 59. OFWAT, Forward programme 2007-2008 to 2009-2010 60. OFWAT, Sustainable Development Action Plan, 2009 61. OFWAT, A sustainable Water Industry to PR09 and beyond. 62. OFWAT Treatment of Renewable Energy, 2008 63. UIC, Rail Transport and Environment, Facts and Figures, June 2008 64. UIC The Environmental Noise Directive, 2008   
65. UIC Occupational Safety Group Meetings 66. UIC Rail Transport and Environment, Facts and Figures, 2008 67. MCA, Sustainable Action Plan 2008-2009. 68. MCA, Our Plans 2008-2009 69. MCA Race Equality Scheme Action Plan for Service Delivery, 2005-2008 70. MCA Health and Safety Publicity Material 71. FRA Freight Noise and Vibration Model  
72. FRA High Speed Ground Transportation Noise and Vibration Impact Assessment Manual  
73. FRA Railroad Advisory Committee 74. FRA, Strategic Plan 2006-2011 75. FRA Transportation System - guidance manual 76. UIPT Handbook on Sustainable Development 77. UIPT Sustainable Development - Making today tomorrow, 2007 78. UIPT Sustainable Development Charter 79. UITP Diverse "Focus Papers" such as Tackling Social Exclusion or low carbon future 
80. UIPT Diversity and Social Development Working Group 81. Department of Transport, Sustainable Case for Rail, 2007 
http://www.rssb.co.uk/pdf/reports/the_case_for_rail_2007.pdf 
82. RSSB Project Specification for Research Review 83. RSSB, Research Programme Management, Sustainable Rail Programme: Foresight Studies 
in Sustainable Development, 2007 
84. RSSB, T674 - Developing metrics and benchmarking for sustainable development in the rail 
industry, 2007 
85. RSSB, T618 - Improving Rail's Energy Efficiency, June 2007 86. RSSB, T438 - The Rail Industry - A Way Forward on Sustainable Development, 2006 87. RSSB, T713 - SRP: Foresight studies in Sustainable Development - Strategic 
implications, December 2007 
88. SDSG, Sustainable rail programme, SD principles Final, 2009 89. RSDG Meeting Minutes 90. Network Rail Corporate Responsibility Report 2007/08 91. Department of Transport, Delivering a Sustainable Railway, 2007 
http://www.dft.gov.uk/about/strategy/whitepapers/whitepapercm7176/hitepapersustainablerai
lway1.pdf 
92. Department of Transport, Towards a Sustainable Railway System, 2007 
http://www.dft.gov.uk/about/strategy/transportstrategy/pdfsustaintranssystem.pdf 
 

## Appendices 1. Benchmarking Frameworks Uk Sustainable Development Strategy - Priorities

In 2005, the Government published 'Securing the Future' - the UK sustainable development strategy.  This sets out the agenda for achieving sustainable development (SD) across the UK and includes five guiding principles and four priorities for National action. This framework aims to identify activities which are in line with the four priority areas.  A summary of how the strategy 
describes each area, along with performance indicators for each, is provided as a guide to identifying activities.  Not all of 
these will be appropriate to the organisation/sector being examined, and activities may be included which, whilst not relating to specific points listed, are nevertheless considered relevant. Indicators have been colour-coded according to ORR's priorities 
(green = highest importance; orange = lowest).
Priority Area
Description
Summary of Indicators
ORR
Sustainable Consumption and 
Production
Achieving more with less Reducing impacts of products and materials across 
their lifecycle
Greenhouse gas emissions
Emissions of pollutants
Environmental Guidance provision to operators (policy and systems)
The Stations Code (clause 14)
Licence conditions (environmental)
Sustainable Development and Aviation 
Environmental Policy in place
Environmental Information Sheets
Sustainable Shipping Conference 2005
Provision of waste management guidance to ports
Regulation of port waste management (plan approval)
Guidance on charges for port waste reception
'Your Ocean' - Nat Maritime Museum exhibition
Developing approach to SD ongoing 2005-8
Work with the Environment Agency and the Drinking Water Inspectorate to 
ensure companies can meet environmental and drinking water quality 
standards
Climate Change and Energy
Reducing greenhouse gas releases 
Greenhouse gas emissions
Use of renewable/sustainable 
fuels Energy generation and 
consumption
Statutory role to improve efficiency
Developing efficiency and performance strategy/policies
Developing enforcement and penalties policies (including efficiency)
Development of industry performance monitoring
Encouragement of use and development of rail network
Environmental Guidance provision to operators (policy and systems)
Review of RUS
Review of charges under PR2008 (freight and passenger)
Licence conditions (environmental)

## Environmental Information Sheet -Aircraft Emissions

Formal involvement in offshore renewable planning and consent Various research conducted in relation to renewable 
(including effects on systems, navigation)
A sustainable water industry - To PR09  and beyond
- March 07
Development of emissions trading scheme Preparing for the future - Ofwat's climate change policy statement

including aviation within the existing
Recent consultation on "Instructions for Fixed CO2 
by DfT and Defra on development of policy for 
aviation in this scheme

Setting a good example and encouraging others

2008: KPI set for traction energy and CO2, data required by Jan08 
and other KPI such as noise, required by mid08 
2008: reduction of energy use in CAA offices
CAA continue to purchase green electricity / 
improvement in green procurement
- INTERNATIONAL conference on sustainable 
development of city electric transport systems was 
held in Ukraine Oct08; co-organised by the Ministry 
of Housing and Municipal Services of Ukraine and 
UITP's Eurasian Division
Natural Resource Protection and Environmental Enhancement
Understanding environmental limits
Bird populations
Biodiversity conservation
Requirements placed on Network Rail regarding Environmental 
Protection Environmental Guidance provision to operators (policy and systems)
The Stations Code (clause 14)
Licence conditions (environmental) Licence conditions (disposal of land)
Review of the Network Code Part E (Environmental Protection)
Provision of environmental advice in runway 
development
Analysis of environmental impact of airport 
developments
Directorate of Airspace Policy role in determining 
impacts
ERCD provision of expert advice to DfT -same
Economic Regulation Group provision of advice to 
Govt on environmental costs
Safety Regulation Group support for environmental 
certification
CAA Aviation Environmental Co-ordination Group
Environmental Research and Consultancy 
Department
Environmental Information Sheet -Aircraft 
Noise+Fuel Dumping and Contrails , march 07
SRG certification of aircraft - emissions and noise
Development of legislation (eg Marpol, IBC code)
Research - environmental protection (oil spills, waste 
reception, ecology, marine litter)
National Contingency Plan
Marine Pollution Control Unit
Counter Pollution and Response Branch
Pollution response coordination (Marine and Shoreline 

Contribution to research on costs of removing phosphorus from effluents
(with Thames Water)

Environmental enhancement and recovery
Environmental stewardship Agricultural emissions
Integrated policy framework
Land use
Land recycling
Environmental equality

A Sustainable Water Industry - To PR09 and beyond, responses to consultation about sustainable economy, carbon footprint, assessing our policies,etc

Dwelling density
Households and dwellings
Fish stocks
Dec07 Environmental Policy Guidance - Guidance on environmental 
arrangements for licence holders 

Preparing for the future - Ofwat's climate change policy statement

Ecological impacts of air 
pollution Emissions of air pollutants
Sustainable Development & Environmental Duties report, including the sustainable development objectives, policy statement and ORR's 
ways of delivering this policy
River quality Water stress
Further duty under the Natural Environment and Rural Committees 
Act 2006 to have regard to the purpose of conserving biodiversity
Flooding
Noise and vibration
Fuel storage
Land contamination
Diffuse pollution
Electromagnetic radiation impact
2008: Sustainable development operations policy 
statement within Sustainable Development Action Plan 
2008-2009
EMS published
More projects research such as:
- Mapping Sensitive Ecological Sites for National 
Contingency Planning, 
- OSPAR Pilot Project on Monitoring Marine Beach Litter,
- The impact of the Port Waste Reception Facilities 
Regulations 2003  
- Development of a Protocol for the Treatment and 
Disposal of Oily Waste in the UK
- Control of the spread of Non-Indigenous Species through 
Ballast Water 
2008:
Environmental policy committee - terms of reference (Nov 2007) Sustainable development and aviation environmental policy
- Ecosystem Assessment following the Sinking of Tanker ECE - Environmental Risk Criteria 
Sustainable Communities
Creating communities that embody sustainable development at the local level
Active community participation
New statutory role as H&S regulator
H&S Strategy
H&S Enforcement Policy Developing long-term H&S strategy/policies Developing risk-based assessment of H&S approach
Developing measurement and reporting framework for H&S
Developing Intervention Plans (2006-07) to ensure workers/public 
H&S HMRI H&S inspections Track Worker Safety Committee Encouragement of use and development of rail network
'Managing Fatigue in Safety Critical Work' - guidance HMRI inspections on route crime Route Crime Reduction and Mitigation Groups www.trackoff.org
HMRI strategy on route crime (2006-9) Partnership on Work Related Violence
Licence conditions (disability) Licence conditions (discrimination) Code of practice for disabled people
RSPG - various Rail Guidance Document - Route Crime - Lineside Security Rail Guidance Document - Route Crime - Lineside Materials Rail Guidance Document - Violence to Staff
Rail Guidance Document - Noise at Work in the Railway IndustryCV
Rail Guidance Document - Vibration at Work RIAC Railway Safety and Statistical Report (2007) The Safety and 
Economic Regulator of Britains railways (ORR)  
Safety Regulation Group (SRG)
Safety Intervention Programme
Annual Safety Plan
Safety research in relation to regulatory activity
Aviation Health Unit
CAA Safety Award Chair of steering group on aviation OH&S
'Travelling Safely' leaflet
'Icefalls' leaflet
CAA Cabin Safety Office inspections
46 Industry Consultative Committees
Airworthiness approval
Safety indicators (reporting)
Large Commercial Yacht Code
Research - safety, accident prevention (e.g. vessel 
stability, lifeboat design, human error)
Coastguard operations
'Sea smart' - public safety
Seafarer training/information provision (H&S, Medical)
COC/CEC verification
Wide range of safety-related guidance for industry and 
public
Marine certification and inspection
The Merchant Shipping( Special Measures to enhance 
maritime safety regulations, 2008.
Code of Working Practices for Merchant seamen
Health and Safety Alerts

Guaranteed Standards Scheme (including customer compensation)
Memorandum of understanding between the office of water services and the health and safety executive Work on ensuring affordability (for households, including low income)
Encouraging awareness of the scheme supporting vulnerable group customers Working with the Water UK debt focus group Monitoring of companies' handling of telephone calls Working to give communities power and say in decisions Working in partnership
2007-2008 Annual report and resource accounts. The Safety and Economic Regulator of Britains Railways. Promoting Safety and Value in Britains Railways: ORR Strategy for 2009-2014. Starting Mainline Rail Operations: A guide to the Regulatory framework from transport Ofgem operations Environmental Policy Statement Commission on Sustainable Development Issue Briefs (inc H&S, environmental, noise)
FRA Environmental Impact Assessment of projects or actions sponsored or taken by the Agency Encouragement of Environmental Management Hazardous Materials:
Hazardous Materials Incident Reduction Program Tank Car Facility Conformity Assessment Program Tank Car Owner Maintenance Program Evaluations Spent Nuclear Fuel and High-Level Nuclear Waste Program Railroad Industrial Hygiene Program Rulemaking, Approvals, and Exemptions Guidance on assessing noise and vibration impacts  
FRA Office of Safety enforces the Railroad Noise Emissions Compliance Regulation High Speed Ground Transportation Noise and Vibration Impact Assessment Manual CREATE Freight Noise and Vibration Model Analytic model to assess the noise impact of train horns Final Rule on the Use of Locomotive Horns at Highway-Rail Grade Crossings Train horn noise quiet zones Docket Management System Transportation System - guidance manual, positive train control Environmental Impact Assessments for significant policy proposals FRA Departmental Environmental Policies The FRA has a hazardous materials safety program and EPA has other regulations dealing with hazardous materials.

FRA Environmental Impact Assessment - FRA considers the potential for environmental impact resulting from projects or actions sponsored or taken by the Agency.

State Rail Safety Participation Program Switching Operations Fatality Analysis (SOFA) 
Rail Integrity Task Force 
'Operation Lifesaver' - public rail safety education programme School Bus Safety Alert - information for bus drivers Truck Driver Safety Alert - information for truck drivers Technical Bulletins (safety for workers)
Safety Advisories Emergency Orders (safety) - Safety Directives Hazardous materials safety program Hazardous Materials Transportation Program - research Partnerships in Domestic and International Standards-Related Organizations (e.g., AAR, ASME, TDG/CGSB) 
Education, Safety Assurance, Compliance, and Accident Investigation Five Year Strategic Plan for Railroad Research, Development and Demonstrations FRA university research grants program Office of Civil Rights Programme - Specific environmental justice role Publications, studies and reports( Reports to congress, grade crossing, accidents, SACP, Employee fatalities, ECP brakes, fatigue management, other reports, archive).

UITP leaflet, may 07, Tackling Social Exclusion The Role of Public Transport Working groups: Diversity and social development  / Indicators / Climate change Manual for the development of bus transport system safety management.

E-Rail (incl improving training access for the disabled, for instance people with impaired vision) Delinquency, vandalism, feeling insecurity - 'Training and behaviour in the face of aggression and prevention of violence. Competency transfer project Additional ongoing noiser and safety research projects.

Regional & Local Sustainability Appraisal
In 2005, the UK Government published guidance to assist regional and local planning bodies in carrying out sustainability appraisal (SA) 
of strategies and development plans, in order to meet the requirements of the European Strategic Environmental Assessment Directive.  
Elements of SA can be considered relevant when examining outward-facing aspects of regulatory bodies (such as policies, industry 
guidance etc).  In particular, the framework below uses the headline SA objectives outlined in the Government's guidance.  Objectives 
have been colour-coded according to ORR's priorities (green = highest importance; orange = lowest).  
Headline Objective
Selected Summary Indicators
ORR
CAA
MCA
OFWAT
OFGEM
UIC
UIPT
FRA
Social
To reduce poverty, social exclusion and health inequalities
Income levels Qualifications
UITP leaflet, may 07, Tackling 
Social Exclusion The Role of 
The FRA Office of Civil Rights is responsible for civil rights compliance and monitoring to ensure non-discrimination 
in passenger railroad services.
Public Transport - including good practice examples, 
recommendations and tools
Diversity and social development 
working group 
 
To improve the health of the population overall
Accidents Illness Access to green space Transport options
Rail Guidance Document - Noise at 
Work in the Railway Industry
Rail Guidance Document - Vibration 
at Work RIAC RSPG - various
Safety Regulation Group Safety Intervention Programme
Annual Safety Plan
Safety research in relation to 
regulatory activity Aviation Health Unit
CAA Safety Award
Chair of steering group on 
aviation OH&S
'Travelling Safely' leaflet 'Icefalls' leaflet
Air Worthiness Approval
CAA Cabin Safety Office 
inspections
Research - accident prevention, 
safety Coastguard operations 'Sea smart' - public safety
COC/CEC verification
Wide range of safety-related 
guidance for industry and public
MGN/MIN/MSNs
Marine certification and inspection
Memorandum of understanding between the office of water services 
and the health and safety executive
Safety Platform Human Factors Working Group
Occupational H&S Group
UIC leaflets on standards of competency and safe 
working practices
UIC Safety database
"SafeCulture" method and toolkit
SAFECOR - Harmonised Operational Safety on 
thematic Network in railway systems

Promotion and regulation of safety Automated Track Inspection Program (ATIP) 
Collision Analysis Working Group (CAWG) 
DOT National Crossing Inventory (Outreach) 
Drug and Alcohol Program Highway-Rail Grade Crossing and Trespassing Prevention Programs Railroad Safety Advisory Committee (RSAC) 
Railroad Safety Board Regulatory Overview Research & Development Safety Improvement and Development Team (SIDT) 
State Rail Safety Participation Program Switching Operations Fatality Analysis (SOFA) 
Rail Integrity Task Force 
'Operation Lifesaver' - public rail safety education programme School Bus Safety Alert - information for bus drivers Truck Driver Safety Alert - information for truck drivers Technical Bulletins (safety for workers)
Safety Advisories Emergency Orders (safety)
Safety Directives Hazardous materials safety program Partnerships in Domestic and International Standards-
Related Organizations (e.g., AAR, ASME, TDG/CGSB) 
Education, Safety Assurance, Compliance, and Accident Investigation Hazardous Materials Transportation Program - research To improve the education and skills of the population overall

Qualifications/skills/training
Statutory programme of inspection of schools, 
local authorities, teacher training providers, 
child minders and day-care providers, 
colleges Comprehensive inspection reports for parents
Joint area reviews
'Inclusion: does it matter where pupils are 
taught? Provision and outcomes in different 
settings for pupils with learning difficulties and disabilities' - report

Issue Briefs (inc H&S, environmental, noise)

| To provide everybody with the opportunity to        | Homelessness   |
|-----------------------------------------------------|----------------|
| Range/affordability of housing                      |                |
| Unfit homes                                         |                |
| Environmental Information                           |                |
| Sheets - House Purchases                            |                |
| Respect our Wrecks' initiative                      |                |
| live in a decent home                               |                |
| To reduce anti-social activity                      | Crime          |
| Fear of crime                                       |                |
| Noise levels                                        |                |
| Noise concerns                                      |                |
| Rail Guidance Document - Route                      |                |
| Crime - Lineside Security                           |                |
| Rail Guidance Document - Route                      |                |
| Crime - Lineside Materials                          |                |
| Rail Guidance Document - Violence                   |                |
| to Staff                                            |                |
| Implementation of security                          |                |
| policies                                            |                |
| Development of a policy on alcohol and drug         |                |
| prevention in the workplace                         |                |
| Benchmarking of assaults on staff and prevention of |                |
| assaults                                            |                |
| Security Group                                      |                |
| COLPOFER (Cooperation between railway police        |                |

The FRA Office of Civil Rights is responsible for civil rights compliance and monitoring to ensure non-discrimination in passenger railroad services.

To encourage a sense of community 
identity and welfare
Social participation Voluntary activity Ethnic relations
Public influence on decisions
Customer Correspondence Team
Environmental Information 
Sheets
Adopt a Wreck' initiative
UITP Youth Project Awards
2008: CAA's Air Travel 
Organiser's Licensing scheme protecting holidaymakers against financial failures of licensed tour operators
To offer everybody the opportunity for rewarding and satisfying employment
Earnings Equal opportunity Hours
Licence conditions (discrimination)
2008: CAA's Equality and Diversity Policy
Flexible and family-friendly working 
Policy
International Training Group
Competency transfer project
International Rail Activities Information Session (SIAFI) 'New Railway Environments: New Competencies' training seminars
Diversity Initiative working group Public Transport International 
publication (incl SD, safety)
Training programme for public 
transport managers

Equal Employment Opportunity Policy and Management

| To improve the quality of where people live   |
|-----------------------------------------------|
| Quality of surroundings                       |
| Environmental Information                     |
| Sheets - House Purchases                      |
| CAA Aviation Property Search                  |
| Service                                       |
| To improve accessibility to essential         |
| services and facilities                       |

Access to key services Charter on Rail Passenger Services (incl safety, security, cleanliness, mobility/access, language)
CREATE: Chicago Region Environmental and Transportation Project: http://www.createprogram.org/ 
Public Private Partnership. CREATE will invest $1.5 billion in critically needed improvements to increase the efficiency of the region's rail infrastructure and the quality of life of Chicago-area residents. 

To improve accessibility for those in most need Costs of transport Rural access Disabled access

Licence conditions (disability)
Code of practice for disabled people
Routeing Guide
Application of Completion Act
Disability Working Group (DWG) - Disability Equality 
Scheme 2008-2011
Work on ensuring affordability (for 
households, including low income)
Encouraging awareness of the scheme 
supporting vulnerable group customers

E-Rail (incl improving training access for the disabled, for instance people with impaired vision)
Partner in European Year of People with Disabilities Environmental To reduce the effect of traffic on the environment Journey length Goods transport Transport modes/reasons

Routing Guide Freight charging policy
Environmental Information 
Sheet - Aircraft Noise 
SRG certification of aircraft - noise
Research - environmental protection + Environmental Risk 
Criteria Projects research ongoing
Vessel Traffic Monitoring and 
Reporting Requirements - recent consultation
Sustainable Action Plan, Living within environmental limits Ofwat's climate change policy 
statement, climate change

The Environmental Advisory Group Internal Sustainable Development Action Plan 08-09, Travel UIC leaflet 345 'Environmental specifications for new rolling stock'
EGNV - Expert Group Noise and Vibration Environment Platform Core Group Environment Experts groups Position paper on the limits of noise pollution for new rolling stock Research on noise (technical tests/evaluation e.g. 

brake pads)
Workshop - Rail Freight Noise Abatement in Europe UIC sub-commission on Noise and Vibrations Rail Freight Noise Abatement in Europe Workshop Energy, Noise, Pollution and Electromagnetic research REPID Network - environmental indicators
"The way to sustainable mobility" - report Research on environmental costs of transport www.railway-mobility.org The Environmental Noise Directive Focus - UIC Noise Network/ UIC Action Programme.

UIC run environmental workshop - Noise Reduction Freight traffic. 

Ecopassenger, Eco Transit Rail Transport and  Environment - Facts and Figures - 
June 2008. 

UITP/UNEP TV advert on public transport and environmental advantages Participation in domestic forums covering a wide range of environmental issues including Brownfield's, noise, invasive species, climate change and community liveability A low carbon future with public transport leaflet with recommendations,etc Issue Briefs (inc H&S, environmental, noise)
FRA Environmental Impact Assessment of projects or actions sponsored or taken by the Agency Encouragement of Environmental Management Guidance on assessing noise and vibration impacts  
FRA Office of Safety enforces the Railroad Noise Emissions Compliance Regulation High Speed Ground Transportation Noise and Vibration Impact Assessment Manual CREATE Freight Noise and Vibration Model Analytic model to assess the noise impact of train horns Final Rule on the Use of Locomotive Horns at Highway-
Rail Grade Crossings Train horn noise quiet zones Tool kit for reducing carbon emissions from transport Climate change working group
2ND Sustainable Development Conference - Making tomorrow today UITP Mobility and City Transport exhibition. 

| To improve water quality      |
|-------------------------------|
| Dangerous substances in water |
| Nutrients in water            |
Research - environmental National Contingency Plan Marine Pollution Control Unit Counter Pollution and Response 

storm sewage in Thames Tideway (with Thames Water) Participating in Defra-led working Hazardous Materials:
Hazardous Materials Incident Reduction Program Tank Car Facility Conformity Assessment Program Tank Car Owner Maintenance Program Evaluations Spent Nuclear Fuel and High-Level Nuclear Waste Program Railroad Industrial Hygiene Program Rulemaking, Approvals, and Exemptions 

| To improve air quality        |
|-------------------------------|
| Sheet - Aircraft Emissions    |
| +Air Proximity Hazards,       |
| AIRPROX  - march07            |
| SRG certification of aircraft |
| emissions                     |

To maintain and enhance biodiversity, flora and fauna

Species populations Habitat changes Protected species
Conservation measures Designated sites Abstraction
Woodland cover
Licence conditions (disposal of land)
Research - environmental protection Projects research ongoing.
Current consultation on the implementation of reactive on ship 
source pollution

To maintain and enhance the quality of landscapes and townscapes

New building Vacant/derelict land Land restoration and care
Landscape features
Chemical releases Litter/cleanliness
Licence conditions (disposal of land)
Worked with Defra on code of practice 
odour nuisance Ofwat's climate change policy 
statement, land management
To conserve and where appropriate 
enhance the historic environment
Loss/damage to listed buildings, monuments, 
historic parks, landscapes etc
Loss of conservation areas
Loss/damage to historic view lines
Licence conditions (disposal of land)
Licence exemptions to heritage 
railway operators
To reduce contributions to climate change
Greenhouse gas emissions
Energy use Renewable energy/fossil fuel use Efficiency Ozone depletion
Environmental Information 
Sheet - Aircraft 
Emissions+Fuel Dumping and 
Contrails march07 SRG certification of aircraft - emissions
Internal monitoring and targeting - SDAP 08-09 and targets
SDAP targets 2008-2009, Climate change and 

energy efficiency UIC Diesel Action Plan Rail Diesel Study Railway Energy Efficiency Conference/Project Evaluation of Energy Efficiency Technologies for Rolling Stock and Train Operation of Railways 
(EVENT) Knowledge Management for Energy-Efficiency Technologies of Railways (EVENT COM Tool) - 
database Railway and energy information day Car-Sharing Platform, working groups:
Standardising Car Sharing Promoting Car Sharing Improving Cooperation between Public Transport and Car Sharing FRA Fact Sheets Participation in domestic forums covering a wide range of environmental issues including Brownfield's, noise, invasive species, climate change and community liveability.

Recent consultation on 
"Instructions for Fixed CO2 
Systems" related to fixed gas fireextinguishing systems
2008: reduction of energy use in CAA offices CAA continue to purchase 
green electricity / improvement 
in green procurement

Partner in European Mobility Week/car-free day To avoid, reduce and manage flood risk Development in areas at risk To provide for sustainable sources of water supply

Water leakage Abstractions Reduction in consumption
Work with the Environment Agency and 
Internal SDAP targets 08-09, water
the Drinking Water Inspectorate to 
ensure companies can meet 
environmental and drinking water 
quality standards Set price limits to ensure safe, reliable service
Enforcement of licence conditions
Guaranteed Standards Scheme 
(including customer compensation)
Modelling of shared water resources (working with EA) Member of the Water Saving Group
Lead sub-group on water efficiency best practice Working with Water wise
Sponsoring economic research category in EA 2006 Water Efficiency 
Awards (widened to include non- and 
household initiatives Ensured investment (£3.5 billion - sewerage; £2 billion - drinking water 
quality)

Ofwat's climate change policy statement, leakage

| To minimise the production of waste                       | Waste raisings               |
|-----------------------------------------------------------|------------------------------|
| Recycling                                                 |                              |
| Hazardous waste                                           |                              |
| Use of aggregates                                         |                              |
| Materials consumption                                     |                              |
| Provision of waste management                             |                              |
| guidance to ports                                         |                              |
| Regulation of port waste                                  |                              |
| management (plan approval)                                |                              |
| Guidance on charges for port                              |                              |
| waste reception                                           |                              |
| Diverse projects research ongoing                         |                              |
| such as the development of a                              |                              |
| protocol for the treatment and                            |                              |
| disposal of oily waste in the UK                          |                              |
| Internal SDAP targets 08-09, waste                        |                              |
| To conserve soil resources and quality                    | Loss of soils to development |
| Contaminated land                                         |                              |
| The Stations Code (clause 14)                             |                              |
| Licence conditions (environmental)                        |                              |
| Economic                                                  |                              |
| To encourage sustained economic growth                    | Competitiveness              |
| Productivity                                              |                              |
| Relative employment/growth (to other sectors)             |                              |
| Research and development in technology                    |                              |
| Improving charges structure to                            |                              |
| provide incentives                                        |                              |
| Published framework for investment                        |                              |
| Review of charges under PR2008                            |                              |
| CAA Economic Regulation                                   |                              |
| Group                                                     |                              |
| Set price limits on companies to                          |                              |
| encourage efficiencies                                    |                              |
| Approval of charging schemes                              |                              |
| Approval of companies' codes of                           |                              |
| practice                                                  |                              |
| Incentive-based regulation                                |                              |
| Monitoring of company performance                         |                              |
| Awards made to top water company                          |                              |
| reporters                                                 |                              |
| Monitoring companies for cross-                           |                              |
| subsidy                                                   |                              |
| Water supply licensing (market                            |                              |
| regulation)                                               |                              |
| Enforcement of Competition Act 1998                       |                              |
| Ofgem statement on sustainable development                |                              |
| (low carbon economy / technologies)                       |                              |
| Transport economics working                               |                              |
| group                                                     |                              |
| Intelligent Railroad Systems (incl impacts on efficiency, |                              |
| emissions, safety)                                        |                              |
| 2008: General Aviation                                    |                              |
| Consultative Committee (CAA                               |                              |
| and GA)                                                   |                              |
| Sustainable Action Plan, Achieving a                      |                              |
| sustainable economy                                       |                              |
| Ofwat policy climate change statement,                    |                              |
| Innovation                                                |                              |
| Setting price limits for 2010-15:                         |                              |
| Framework and approach                                    |                              |
| To reduce disparities in economic                         |                              |
| performance                                               |                              |
| Regional/local variations in performance                  |                              |
| Reduction in inequalities                                 |                              |
| Comparative costs                                         |                              |
| Developing an economic                                    |                              |
| enforcement policy                                        |                              |
| Application of Competition Act                            |                              |
| Relating to Railways                                      |                              |
| Costs and charges review                                  |                              |
| Modifications to charges in                               |                              |
| favour of smaller operators                               |                              |
| CREATE: Chicago Region Environmental and                  |                              |
| Transportation Project                                    |                              |
| To encourage and accommodate both                         |                              |
| indigenous and inward investment                          |                              |
| Encouragement of business start up                        |                              |
| Encouragement of investment                               |                              |
| Availability of land and property for development         |                              |

CREATE: Chicago Region Environmental and Transportation Project To encourage patterns of  movement in support of economic growth Commuting patterns Accessibility to work Alternative transport modes Journey times Freight distribution efficiency Review of charges under PR2008 
(freight and passenger)
Freight charging policy CREATE: Chicago Region Environmental and Transportation Project Railroad Rehabilitation and Improvement Financing Program(RRIF) :     * Acquire, improve, or rehabilitate intermodal or rail equipment or facilities, including track, components of track, bridges, yards, buildings and shops;
    * Refinance outstanding debt incurred for the purposes listed above; and
    * Develop or establish new intermodal or railroad facilities To enhance the image of the area as a business location Attraction of investment Attraction of workforce To improve the social and environmental performance of the economy Ethical trading Environmental Management Systems Employee relations and management practices CAA's Investors in People Sustainable development workshop 
(stakeholders, water industry, customer, environmental groups)
European Railways Purchasing Conference (ERPC) 
ethical standards Sustainable Development Workshops Making tomorrow today, mar ch 
07 includes reporting

## Bs 8900 Comparison

BS 8900:2005 'Guidance for Managing Sustainable Development' has been developed by BSi British Standards to provide guidance on managing Sustainable Development (SD) to enhance organisational performance and effectiveness.  The framework below is based on Section 4 of the standard: 'Putting Sustainable Development into Practice' which includes particular actions (highlighted in blue) against which benchmarking can be conducted.

|                                                |                            |                                             |       |       | Reference   | Clause   | Summary Description   |
|------------------------------------------------|----------------------------|---------------------------------------------|-------|-------|-------------|----------|-----------------------|
| ORR                                            | CAA                        | MCA                                         | OFWAT | OFGEM | UIC         | UIPT     | FRA                   |
| 4.1                                            | The Organisation           |                                             |       |       |             |          |                       |
| Prepares and maintains an SD statement         |                            |                                             |       |       |             |          |                       |
| which forms the foundation for the             |                            |                                             |       |       |             |          |                       |
| organisation's SD activities and helps align   |                            |                                             |       |       |             |          |                       |
| primary purpose with related SD activities     |                            |                                             |       |       |             |          |                       |
| Health, Safety &                               |                            |                                             |       |       |             |          |                       |
| Environmental                                  |                            |                                             |       |       |             |          |                       |
| Policy statement;                              |                            |                                             |       |       |             |          |                       |
| Equality &                                     |                            |                                             |       |       |             |          |                       |
| Diversity Policy                               |                            |                                             |       |       |             |          |                       |
| statement                                      |                            |                                             |       |       |             |          |                       |
| Sustainability                                 |                            |                                             |       |       |             |          |                       |
| Policy statement                               |                            |                                             |       |       |             |          |                       |
| Sustainable                                    |                            |                                             |       |       |             |          |                       |
| Development and                                |                            |                                             |       |       |             |          |                       |
| Aviation                                       |                            |                                             |       |       |             |          |                       |
| Environmental                                  |                            |                                             |       |       |             |          |                       |
| Policy in place                                |                            |                                             |       |       |             |          |                       |
| 2008: similar                                  |                            |                                             |       |       |             |          |                       |
| 4.2                                            | The Issues                 |                                             |       |       |             |          |                       |
| 4.2.1                                          | General                    | Ongoing systematic stakeholder              |       |       |             |          |                       |
| engagement is intrinsic to SD                  |                            |                                             |       |       |             |          |                       |
| 4.2.2                                          | Stakeholder Identification | Defines and identifies stakeholders and     |       |       |             |          |                       |
| Has defined                                    |                            |                                             |       |       |             |          |                       |
| stakeholders for                               |                            |                                             |       |       |             |          |                       |
| consultation on SD                             |                            |                                             |       |       |             |          |                       |
| their representative organisations, clarifying |                            |                                             |       |       |             |          |                       |
| their interest and relationship with the       |                            |                                             |       |       |             |          |                       |
| organisation                                   |                            |                                             |       |       |             |          |                       |
| 4.2.3                                          | Stakeholder Engagement     | Engages with stakeholders to understand     |       |       |             |          |                       |
| the social, economic and environmental         |                            |                                             |       |       |             |          |                       |
| impacts and risks of the organisation's        |                            |                                             |       |       |             |          |                       |
| activities                                     |                            |                                             |       |       |             |          |                       |
| Is about to consult                            |                            |                                             |       |       |             |          |                       |
| stakeholders on                                |                            |                                             |       |       |             |          |                       |
| SD                                             |                            |                                             |       |       |             |          |                       |
| Engages with staff                             |                            |                                             |       |       |             |          |                       |
| 2008: same -                                   |                            |                                             |       |       |             |          |                       |
| involve staff to                               |                            |                                             |       |       |             |          |                       |
| influence CAA''s                               |                            |                                             |       |       |             |          |                       |
| work                                           |                            |                                             |       |       |             |          |                       |
| 4.3                                            | Capability                 |                                             |       |       |             |          |                       |
| 4.3.1                                          | General                    | For the principles of SD to be put into     |       |       |             |          |                       |
| practice, the organisation requires            |                            |                                             |       |       |             |          |                       |
| appropriate resources and a range of           |                            |                                             |       |       |             |          |                       |
| comptencies                                    |                            |                                             |       |       |             |          |                       |
| 4.3.2                                          | Resource Allocation        | Allocates appropriate resources (financial, |       |       |             |          |                       |
| human and manufactured) to achieve the         |                            |                                             |       |       |             |          |                       |
| SD objectives                                  |                            |                                             |       |       |             |          |                       |
| CAA Aviation                                   |                            |                                             |       |       |             |          |                       |
| Environmental co-                              |                            |                                             |       |       |             |          |                       |
| ordination Group                               |                            |                                             |       |       |             |          |                       |
| Environmental                                  |                            |                                             |       |       |             |          |                       |
| Information Sheet,                             |                            |                                             |       |       |             |          |                       |
| Roles and                                      |                            |                                             |       |       |             |          |                       |
| Responsabilities -                             |                            |                                             |       |       |             |          |                       |
| march07                                        |                            |                                             |       |       |             |          |                       |
| 4.3.3                                          | Competence Building        | Identifies the learning and development     |       |       |             |          |                       |
| needs (partic. SD) of employees; provides      |                            |                                             |       |       |             |          |                       |
| resources to develop competence; reviews       |                            |                                             |       |       |             |          |                       |
| existing learning and development              |                            |                                             |       |       |             |          |                       |
| programmes in line with SD                     |                            |                                             |       |       |             |          |                       |
| Has a training                                 |                            |                                             |       |       |             |          |                       |
| policy (not                                    |                            |                                             |       |       |             |          |                       |
| specifically in                                |                            |                                             |       |       |             |          |                       |
| relation to SD)                                |                            |                                             |       |       |             |          |                       |
| Environmental                                  |                            |                                             |       |       |             |          |                       |
| awareness raising                              |                            |                                             |       |       |             |          |                       |
| events for staff                               |                            |                                             |       |       |             |          |                       |
| Greening                                       |                            |                                             |       |       |             |          |                       |
| Operations - Local                             |                            |                                             |       |       |             |          |                       |
| Action Plan                                    |                            |                                             |       |       |             |          |                       |
| Ofgem                                          |                            |                                             |       |       |             |          |                       |
| statement on                                   |                            |                                             |       |       |             |          |                       |
| sustainable                                    |                            |                                             |       |       |             |          |                       |
| development                                    |                            |                                             |       |       |             |          |                       |
| /Ofgem                                         |                            |                                             |       |       |             |          |                       |
| Operations                                     |                            |                                             |       |       |             |          |                       |
| Environmental                                  |                            |                                             |       |       |             |          |                       |
| Policy                                         |                            |                                             |       |       |             |          |                       |
| Statement                                      |                            |                                             |       |       |             |          |                       |
| /SDAP targets                                  |                            |                                             |       |       |             |          |                       |
| Making tomorrow                                |                            |                                             |       |       |             |          |                       |
| today, mar ch 07                               |                            |                                             |       |       |             |          |                       |
| includes reporting                             |                            |                                             |       |       |             |          |                       |
|                                           | 4.4                 | Management                      |
|-------------------------------------------|---------------------|---------------------------------|
| 4.4.1                                     | General             | SD can be managed using various |
| techniques, including introducing SD      |                     |                                 |
| elements into existing management         |                     |                                 |
| systems                                   |                     |                                 |
| 4.4.2                                     | Assessing Risks and |                                 |
| Opportunities                             |                     |                                 |
| Undertakes an assessment which identifies |                     |                                 |
| impacts and issues, establishes their     |                     |                                 |
| significance, and prioritises actions to  |                     |                                 |
| maximise opportunities and minimise risks |                     |                                 |
Supplier Audits
| 4.4.3                                         | Identifying Performance    |
|-----------------------------------------------|----------------------------|
| Indicators                                    |                            |
| Identifies, defines effective ways to         |                            |
| measure, and implements key indicators in     |                            |
| relation to the SD objectives                 |                            |
| Targets for                                   |                            |
| energy, water,                                |                            |
| waste, paper,                                 |                            |
| transport,                                    |                            |
| purchasing                                    |                            |
| 4.4.4                                         | Achieving Progress         |
| performance against the SD objectives and     |                            |
| Has indicators in                             |                            |
| relation to aspects                           |                            |
| of equality -                                 |                            |
| KPIs set                                      |                            |
| indicators; integrates the objectives through |                            |
| inclusion in job responsibilities and         |                            |
| personal objectives; manages performance      |                            |
| equitably in relation to any other            |                            |
| organisational objectives                     |                            |
| 4.5                                           | Review                     |
| 4.5.1                                         | General                    |
| review and reporting processes                |                            |
| 4.5.2                                         | Review of Strategy         |
| appropriate intervals, or following           |                            |
| significant organisational change             |                            |
| 4.5.3                                         | Operational Review         |
| activities and reports internally and         |                            |
| externally on indicators                      |                            |
| FRA also                                      |                            |
| conducts                                      |                            |
| environmental                                 |                            |
| reviews of                                    |                            |
| pending                                       |                            |
| actions.                                      |                            |
| 4.5.4                                         | Follow-up                  |
| dealt with and implements the changes         |                            |
| required for continual improvement            |                            |
| 4.6                                           | Building Confidence        |
| May establish processes for building          |                            |
| confidence in the management of SD,           |                            |
| including subjecting aspects of this to       |                            |
| verification                                  |                            |
| Policy to monitor                             |                            |
| and report health                             |                            |
| and safety and                                |                            |
| environmental                                 |                            |
| performance                                   |                            |

Source: BSi British Standards

## 2. Summary Of Regulators Duties

| Regulator                                                          | Primary Regulatory Function    |
|--------------------------------------------------------------------|--------------------------------|
| Benchmarking?                                                      |                                |
| CAA                                                                |                                |
| Regulates the charges paid by airlines at airports designated by   |                                |
| the Government (currently Heathrow, Gatwick, Stansted and          |                                |
| Manchester) and deals with complaints about the conduct of         |                                |
| airports.                                                          |                                |
| Regulates air traffic control services.                            |                                |
|                                                                    |                                |
| Determining policy for the use of UK airspace so as to             | Yes                            |
| meet the needs of all users, having regard for                     |                                |
| national security, economic and environmental                      |                                |
| factors, while maintaining a high standard of safety.              |                                |
| Postcomm                                                           |                                |
| Regulates the postal market, to ensure that licensed postal        |                                |
| operations-including Royal Mail - meet the needs of their          |                                |
| customers throughout the UK.                                       |                                |
|                                                                    |                                |
|                                                                    |                                |
| Postcomm have no regulatory environmental duties                   | No                             |
| and there is no sustainability information available on            |                                |
| their website.                                                     |                                |
| Ofgem                                                              |                                |
| Helping to secure Britain's energy supplies by promoting           |                                |
| competitive gas and electricity markets - and regulating them so   |                                |
| that there is adequate investment in the networks.                 |                                |
| Contributing to the drive to curb climate change and               | Yes                            |
| other work aimed at sustainable development by, for                |                                |
| example:                                                           |                                |
| Helping the gas and electricity industries to achieve              |                                |
| environmental improvements as efficiently as                       |                                |
| possible; and                                                      |                                |
| Taking account of the needs of vulnerable customers,               |                                |
| particularly older people, those with disabilities and             |                                |
| those on low incomes.                                              |                                |
|                                                                    |                                |
| Ofwat                                                              |                                |
| Ofwat (The Water Services Regulation Authority) is the economic    |                                |
| regulator of the water and sewerage companies in England and       |                                |
| Wales. They ensure that companies provide household and            |                                |
| business customers with a good quality service and value for       |                                |
| money.                                                             |                                |
|                                                                    |                                |
| Ofwat make sure that water companies can meet the                  | Yes                            |
| social, financial and environmental challenges of the              |                                |
| future. Each company must deliver high quality                     |                                |
| services while causing as little damage as possible to             |                                |
| the environment.                                                   |                                |
| Ofcom                                                              |                                |
| Ofcom is the regulator for the UK communications industries, with  |                                |
| responsibilities across television, radio, telecommunications and  |                                |
| wireless communications services.                                  |                                |
|                                                                    |                                |
| Ofcom's specific duties fall into the following areas:             |                                |
| Ensuring the optimal use of the electro-magnetic spectrum          |                                |
| Ensuring that a wide range of electronic communications services   |                                |
| - including high speed data services - is available throughout the |                                |
| Ofcom have no regulatory environmental duties and                  | No                             |
| there is no obvious sustainability information available           |                                |
| on their website.                                                  |                                |
|                                                                    |                                |
|                                                                    |                                |
UK Ensuring a wide range of TV and radio services of high quality 
and wide appeal  
Maintaining plurality in the provision of broadcasting  
Applying adequate protection for audiences against offensive or harmful material Applying adequate protection for audiences against unfairness or 
the infringement of privacy.  
FSA 
The FSA is an independent non-government body that regulates 
the financial services industry in the UK. The FSA's aim is to promote efficient, orderly and fair financial markets and help retail financial service consumers get a fair deal. 
 
No regulator requirements; however has an 
No 
organization they are committed to good environmental practice. The FSA aim to reduce their environmental impact and contribute to a healthier environment.  

 
Pensions Regulator 
Regulates the Work-Based Pension Schemes to ensure that: 
benefits of members are protected, there is good administration 
of the schemes and that claims for compensation from the 
Pension Protection Fund are reduced.  
 
No regulator requirements. No 
No 
sustainability/environmental pages on the website.  
Office of Fair Trading 
Is the UK's consumer and competition authority. It regulates 
markets to ensure that they work well for consumers and that 
customers have as much choice as possible across all different 
sectors of the marketplace.  
The public has a right of access to environmental 
No 
information held by public authorities and some other organizations. The Office of Fair Trading provides this information to the public upon request. 
The Competition 
Commission 
The CC helps ensure healthy competition between companies in 
the UK for the benefit of companies, customers and the economy.  
__  
No 
 
 
Ofsted 
Ofsted regulates the education sector to achieve excellence in 
the care of children and young people, and in education and skills 
for learners of all ages.  
 
The government wants all schools to become 
No 
sustainable schools by 2020 and there is a 'National Framework for Sustainable Schools'. Ofsted inspect schools to assess teaching about sustainability and progress towards the framework.