Select Committee on Environmental Audit Thirteenth Report


Coverage of the report

11. The questionnaire to departments which underpins Part 1 of the Sustainable Development in Government report has been reproduced accurately and completely by DEFRA on its website. Part 2 of the report also appears to include all departmental responses.

12. The First Annual Report is based on a questionnaire sent out to departments. In response to an earlier recommendation we made, DEFRA have made available both the questionnaire and the complete departmental responses. We welcome the provision of this detailed information. It marks a significant step forward in terms of transparency and accountability, and has enabled us to carry out a significantly more extensive analysis than we could otherwise have done.

13. However, there were occasional gaps or errors in the data. For example, the MoD failed to answer questions 1.4 and 1.5 requesting information on MoD staff resources specifically dedicated to sustainable development. Where there were gaps, it was not possible for us to be certain whether departments had failed to respond to certain questions, not responded because they considered the question irrelevant, simply provided a nil response, or provided a response which has not been made available on the web-site. There were also a few cases where clerical mistakes had been made in inputting data onto the website.

14. We note that departments were asked to complete the questionnaire on-line through secure access to a common server, and that the SDU subsequently drafted Part 1 of the report on the basis of these responses. Where there are gaps or errors in departmental information, we cannot at present be certain as to the cause. We recommend that all departments should provide a printed copy of their responses to both the SDU and EAC. These should be signed by the senior officer who is responsible for sustainable development issues in order to ensure accountability at a sufficiently high level within each department.

Staff resources

15. Part 1 of the departmental questionnaire contains various questions on the size and nature of the department, and the resources specifically devoted to the sustainable development agenda. Our analysis in the table below highlights wide differences between departments, both in absolute and percentage terms.
Dept Number of staffHighest grade of SD staff
Total Staff

(including agencies)

Central SD staff (WTE) Percentage of total staffGrade of most senior SD staff Percentage of his / her time
CO6,044 2.00.03 HEO/SEO100
C&E22,286 2.00.01 SEO100
DCMS702 0.90.13 G710
DEFRA14,252 12.90.09 G520
DfES4,282 2.80.07 G62
DfID1,385 32.22.32 SCS100
DH4,098 2.40.06 G65
DTLR19,500 8.60.04 SCS20
DTI8,762 [no data] G6
DWP129,909 10.20.01 G720
ECGD420 2.00.48 G7100
FCO3,560 48.21.35 SCS303
HMT2,796 2.00.07 G65
HO65,040 7.20.01 G733
IR68,467 1.10.00 SCS5
LCD12,559 0.90.01 SEO50
LOD8,317 1.40.02 SCS10
MoD
ONS3,800 0.30.01 51
Total376,179 1370.04

Notes

1. WTE refers to Whole Time Equivalent.

2. Traditional Civil Service grades range from G1 (the highest) to G7, SEO, HEO, EO and below.

3. The term SCS has been used by some departments to refer to a member of the Senior Civil Service (ie Grade 5 and up). In such cases, the department has not disclosed the specific grade of the staff member.

4. The highest grade of SD staff refers to the highest graded individual(s) who is included in the Central SD staff (WTE) figure. In the case of the FCO, as there are 3 Grade 5s, each of whom devotes 100% of their time to this agenda, and a fourth Grade 5, who devotes only 3% of his/her time to it, the overall percentage figure is 303%. This is unusual, and for most departments there would only be one highest-graded member of staff who devotes only a part of his/her time to this agenda.

16. The amount of staff resources which departments specifically devote to sustainable development ranges widely from 0.0% to 2.3%. As one might expect, DFID leads with over 31 staff, 30 of whom are within its Environmental Policy Department. The FCO has also invested impressive resources in this area with the creation of its own Environment Policy Department, with a staff of 27. A further 21 staff in other parts of the FCO deal with a range of related issues.

17. At the other end of the scale, it is disappointing that the Inland Revenue, with some 68,000 staff, do not even register in percentage terms with only 1.1 WTE staff. Similarly, we are amazed that the ONS appears to have only 0.3 WTE staff devoted to this agenda, despite its involvement in developing the environmental accounts and resource productivity indicators.

18. We also note that the grading of staff involved is relatively low. In the case of seven departments, the highest grade of staff disclosed in this table is grade 7 or lower. In addition, the percentage of time of the most senior grade of staff is limited. For example, the DCMS grade 7 devotes only 10% of his/her time to the sustainable development agenda. In the case of DfES, the percentages for the three highest graded staff (6, 7, and SEO) are 2%, 5% and 10% respectively. Such figures hardly suggest commitment on the part of these departments.

19. The level of staff resources which most departments specifically devote to the sustainable development agenda is very small, reflecting the low priority accorded to it. The grade of staff working on these issues is also relatively low. We would particularly single out DCMS, DfES, DH, IR and ONS as departments within which we would have expected far greater commitment in terms of staff resources in view of the specific challenges which sustainable development poses for those departments.

20. Nine departments state that their sustainable development staff form a separate Sustainable Development Unit or division. (Curiously, DfID and FCO respond negatively to the SDU question even though they have set up dedicated environmental protection divisions.) Seven departments have not set up an SDU or division, and these include DCMS, DfES, HMT, HO and IR. This is surprising and disappointing in view of the potentially important roles these departments should have in relation to sustainable development.

21. Departments were also asked to give details of the senior official responsible for sustainable development issues. We examined the relationship between these staff and the dedicated Sustainable Development teams, and—while the information is extremely limited—it does suggest some anomalies:

22. In the case of both DH and DWP, the senior officer responsible for sustainable development is not located in the departments' central offices alongside the dedicated sustainable development staff. Such an arrangement hardly seems to us conducive to effective operational management on a day to day basis, nor indeed to the need to exert leverage on central policy divisions within the department.

23. More generally, many of the senior officials listed by departments do not appear to be included in the listing of staff resources, suggesting that either the latter is inaccurate or that the time devoted by these senior officials is too small to be measured. There is also no information on whether the senior official responsible for sustainable development is a member of each department's management board. In some cases this is unlikely given the gradings of the senior officials. Interestingly, this information was specifically sought in previous work by the Green Ministers Committee; and the EAC has itself frequently emphasised the need for departmental commitment at a high level.

24. Some departments may argue that sustainable development has been mainstreamed across other policy divisions, and that it is therefore unfair to take the figures they have provided on sustainable development staffing as representative of the priority accorded to this agenda. However, if this really were the case, initiatives such as the creation of EPD within FCO would be pointless and the question itself redundant. It would suggest that either the FCO have got it very wrong, or else that there is a role for a dedicated core of staff devoted to this agenda. We strongly endorse the latter viewpoint and are suspicious of claims that sustainable development has permeated the value structures and outlook of mainstream policy staff. Indeed, evidence elsewhere in this report on the extent of staff training and awareness demonstrates very little commitment. to bringing about such a change.

25. It is unclear what level of commitment and representation exists at a Management Board level as there is no information provided on this topic. Our analysis of staff resources does not inspire confidence that senior management is committed to implementing sustainable development. ENV(G) should probe this area in greater depth by including more searching questions in the 2004 questionnaire.

Greening policy

Objectives and targets

26. The incorporation of environmental aims within departments' objectives and targets represents a key measure of the extent to which the environment is being mainstreamed. The Sustainable Development in Government report explores this area on the basis of a series of questions included in part 2 of the questionnaire. However, a number of these questions were open-ended and subject to a variety of interpretation by departments. There is relatively little 'hard' data, therefore, on which to base firm conclusions.[7]

27. Hardly any departments had set any new objectives or targets in the last year. We could only identify five which were not vacuously general, and of these only three were in any way 'smart'. Many of the departments, in answering the question, referred to initiatives or processes which would more appropriately have been included in responses to other questions. We welcome by contrast the candour of the Home Office in admitting that it had set no new objectives. While we recognise that target setting is not something to be pursued for its own sake, the almost universal failure by departments to set new environmental objectives and targets cannot but reflect insufficient commitment, resources, and priorities in this area.

28. Departments were also asked specifically about Spending Review 2002—in particular, the processes which they had used to produce their Sustainable Development Reports (SDRs). Departmental responses to this question highlight a variety of approaches, and— given the lack of access to the SDRs themselves—it is difficult to assess their effectiveness. Some departments appear to have adopted a systematic and thorough approach. The DTLR, for example, subjected all individual bids to integrated appraisals which would highlight environmental and other impacts, and aggregated the results. Other departments, including the MoD and DEFRA, only applied integrated appraisals to a subset of its bids. We also noted that DEFRA appeared to be the only department to match its top priority spending proposals against the department's objectives and draft PSA targets, and the sustainable development indicators.

29. By contrast, other departments give little or no real information, referring only to liaison and coordination, or to Cabinet Office and Treasury guidance. The response of the Inland Revenue is particularly terse: "SD is included in the Department's report." We find it astonishing that the department made so little attempt to provide an informative answer to the question. This is a matter of particular concern in view of the potential for exploring innovative approaches within the tax system in order to shift the burden of taxation from 'goods' to 'bads'. We are astonished at the terse and unhelpful response provided by the Inland Revenue when asked about the compilation of its Sustainable Development Report. Given the lack of dedicated staff resources within the department, it only serves to reinforce the impression that it is little interested in the sustainable development agenda.

30. Little meaningful information was provided by departments on the extent to which sustainable development had been incorporated within PSA targets. Some departments interpreted sustainable development to encompass all their activities. The CO, DfES and DH responses, for example, focus on social and economic policies relating to human health and education. By contrast other departments such as the MoD and the DTI tried to limit their responses to more environmentally related issues.

31. In view of the wide-ranging nature of responses and their departmental specific focus, we have not attempted to analyse to them. However, we noted with interest some of the responses from individual departments on the extent to which sustainable development was included in their policy objectives:

  • The DCMS stated that it was mainly concerned with indicators on poverty and social exclusion, and education; and that it had no specific sustainable development targets. Yet DCMS has a potentially key role in environmental education and awareness raising so as to bring about fundamental changes in values and behaviour.
  • The DfES acknowledged the need to review how its aims and objectives related to sustainable development and to make these connexions much more specific.
  • The ONS admitted that sustainable development was not covered in its Service Delivery Agreement, and that it has no plans for further developments to incorporate environmental concerns. As we have pointed out elsewhere in this report, the development of effective resource productivity indicators is a major task. Moreover, we would have thought that the ONS would be centrally involved in the review of the Sustainable Development Strategy and its indicators.

32. We find it deplorable that both DCMS and ONS should place so little weight on sustainable development and environmental objectives, as both departments in their respective spheres face significant challenges in this area. This contrasts with the far more positive approach adopted by some other departments, such as DTLR and DfES.

33. In its last Pre-Budget Report, EAC carried out its own analysis of the extent to which environmental objectives and targets had been incorporated within Public Service Agreements as part of Spending Review 2002.[8] In view of the lack of 'hard' information on this score in the Sustainable Development in Government report, we reproduce the results in the following table and have taken the opportunity to make a couple of minor corrections. Excluding those targets which relate to DEFRA, we can only identify four which are primarily environmental out of some 160 targets in total. This is a dismal reflection on the extent to which the environment is being mainstreamed.

Spending Review 2002: analysis of objectives and targets
Department Total number of objectives Total number of Targets Environmental objectivesEnvironmental targets
CO5 60 0
C&E2 40 0
DCMS3 40 0
DEFRA6 102 (note 1) 6 (note 2)
DFES6 100 0
DFID5 50 (note 3) 0 (note 3)
DfT1 71 (note 4) 1 (note 4)
DH2 120 0
DTI5 120 1(note 5)
DWP5 100 0
FCO6 120 (note 6) 1 (note 7)
HMT10 101(note 8) 0
HO6 100 0
IR1 50 0
LCD3 70 0
LOD (CPS)1 30 0
MoD3 70 0
NIO6 40 0
ODPM3 71 (note 9) 1 (note 10)
Sure Start etc0 10 0
Criminal Justice System 35 00
Action against illegal drugs 44 00
Local Government0 150 0
TOTAL86 1705 10
TOTAL (non-DEFRA)80 1603 4 (note 11)

Notes:

1. Objectives I and V. These are overtly environmental. Not included here are objectives III and IV (which include the word 'sustainable' but primarily emphasise other objectives such as competitive markets0; and objective VI (which is primarily health related, though it has a strong environmental component).

2. Targets 2, 3, 5, 6, 7 and 8. Targets 2, 3, 6, 8 are overtly environmental. Target 7 can be included because of the direct impact on energy demand. Target 5 refers to EU support for environmental conservation and rural

development, though it also emphasises a customer focused and competitive farming system. Not included here are target 1 (which relates to promoting sustainable development as a whole), target 4 (productivity related), target 9 (animal health and public welfare) and target 10 (VFM).

3. The objectives and targets of DFID are focused on poverty reduction and health improvements. While these are important components of progress towards sustainable development, they are not per se environmental.

4. DfT has only 1 objective—"reliable, safe and secure transport which respects the environment". Target 6 is a joint target with DEFRA to improve air quality.

5. Target 4. This refers to improving the environment and the sustainable use of natural resources, including through the use of energy saving technologies, and specifically to the joint DTI/DEFRA carbon reduction and greenhouse gas targets. Note, however, that the target begins by citing a simple economic competitiveness target ("to ensure the UK ranks in the top three most competitive energy markets in the EU and G7…").

6. Objective III has not been included. It is to "increased prosperity and a better quality of life in the UK and worldwide, through effective economic and political governance."

7. Target 7. This refers to making globalisation work for sustainable development and also to promoting environmental governance, but is rather wider in scope as it encompasses political and economic objectives.

8. Objective X. The objective is to protect and improve the environment by using instruments that will deliver efficient and sustainable outcomes through evidence-based policies.

9. Objective III. The objective is to help raise the quality of life but the supporting targets are primarily social.

10. Target 5. The target refers to protecting the countryside and to the sustainability of existing towns and cities, though the main emphasis is on achieving a better balance between housing availability and the demand for housing.

11. Of these 4 targets, 2 are shared targets with DEFRA (notes 4&5 above), while the extent to which the remaining two can be classed as environmental is arguable (see notes 7 and 10).

34. Environmental sustainability should constitute an over-arching framework within which policy making is carried out. But departments have made little attempt to incorporate environmental objectives within their high level priorities, and this is reflected in the dearth of environmental targets in the most recent Public Service Agreements. This betrays a lack of commitment to this agenda which complements the lack of resources devoted to it.

Policy Appraisal

35. Policy appraisal is a crucially important area on which EAC has frequently commented before. Two different issues are at stake here—the effectiveness of procedures to ensure that environmental screening and appraisals are carried out at all; and the manner in which environmental appraisals are evaluated. We are also concerned that appraisals should not be seen as a retrospective activity—to be carried out only when the preferred policy option is identified, but that they should be fundamentally incorporated in the initial process of drawing up policy options.

36. It is difficult to obtain objective evidence in this area and the questionnaire responses reflect this, with fairly vacuous answers to some of the questions which allow little scope for meaningful analysis.[9] However, the 2000 Green Ministers Report introduced a requirement on all departments to screen all new policies or policy developments for their environmental effects, and carry out an environmental appraisal if necessary. Departments were also required to maintain a list of such screenings, though it was up to them whether to make these public. [10] EAC regarded this as a significant achievement.

37. In the questionnaire, departments were specifically asked whether they were maintaining a record of screenings as required. In the following table, we have summarized the results, including the results from some other related questions.
Dept Do you maintain a central list of screening outcomes? Number of environmental appraisals published Does your Environmental Management System cover policy?
CONo NoneNo (central dept)
C&EYes [confidential] NoneAssume no
DCMS[no response] NoneNo
DEFRAYes Unclear (move to IPA) No
DfES[no response] NoneNo, but plan to include.
DfIDAssume no NoneNo, but are other procedures.
DHUnclear NoneNo (central dept). Yes (PASA)
DTI[no response] UnclearNo
DTLRNoNone (part of wider appraisal) No
DWPUnclearNone No
ECGDUnclearYes, for some projects Unclear
FCOUnclearNone No
HMTNoNone No
HONoNone No
IRYesYes, as part of Budget Yes
LCDYesNone No
LODNot relevantNot relevant n/a
MoDNo (is planned)None Yes [non-certified system]
ONSNot relevantNot relevant Unclear

38. Most departments are clearly flouting the requirement set by Green Ministers to maintain a list of screenings. Some have failed to answer the question (eg DCMS) or appear to have misunderstood it (eg DTLR). Others have provided rather anecdotal responses which makes it difficult to be certain even where the likelihood is that they are not (eg DH). The lack of any formal systems to maintain such a central record is reflected in the failure of most departmental EMS to encompass policy issues. As a result, with the exception of DETR and some project-specific appraisals carried out by ECGD, virtually no environmental appraisals were carried out during the previous year.

39. In considering this issue, the 2001 Green Ministers Report stated that "it is somewhat disappointing that, despite promotion of environmental appraisal, inclusion in the Policy Makers Checklist and screening systems put in place by departments, relatively few departments beyond DETR have produced published environmental appraisals." It also stated that: "It is possible that departments are making progress, and building environmental considerations into other appraisals, but the extent to which this is happening is not clear." It went on to make the following commitment: "The reasons for the apparent lack of progress on environmental appraisal will be investigated as part of a review of progress with development of integrated appraisal systems in the next year." [11]

40. Yet Part 1 of the Sustainable Development in Government report states only that "there has been a recognition that environmental impacts need to be considered alongside economic and social impacts in the wider context of sustainable development. This year many departments—most notably DTLR and DEFRA—have reported that environmental appraisals are increasingly an intrinsic part of the wider decision making process and therefore keeping a log of appraisals is not a meaningful indicator of how well the department considers environmental issues." [12] This is the only consideration given to this topic in the latest report.

41. The Government therefore appears to be arguing that the move towards integrated appraisal renders the screening requirement redundant, a view which was echoed in the questionnaire responses from some departments. We entirely disagree. EAC supports the move to integrated appraisals, but is concerned over the failure of departments to take environmental screening and appraisal seriously.

42. If departments are indeed carrying out integrated appraisals, it follows that they must be screening new policies for environmental impacts as part of that process. For the Government's commitment to sustainable development to be taken seriously, ENV(G) must restate and rigorously implement the requirement that departments should maintain and make publicly available a central list of new policies, together with the results of screening them for environmental impacts.

43. It is also worth noting that there are various overlapping requirements on departments in terms of different types of appraisal they are obliged to carry out. These include:

  • individual methodologies developed within departments (eg DfT's New Approach to Appraisal)
  • Regulatory Impact Assessments
  • the Strategic Environmental Assessment Directive
  • Green Ministers' screening requirements
  • Treasury policy guidance (eg 'Tax and the Environment')
  • the Treasury 'Green Book'
  • the Cabinet Office 'Policy makers checklist'.

44. DEFRA and some other departments have been developing a so-called "Integrated Appraisal Tool". But this tool is at present little more than a reminder to departmental staff that they must consider and, where relevant, carry out various other forms of appraisal. There are also some significant conceptual difficulties. In particular, EAC has recently highlighted a major tension between the increasing emphasis the Treasury is placing on evaluating environmental impacts in financial terms, and the non-monetary approaches used, for example, by the DfT in its NATA methodology. [13]

45. There is a variety of overlapping requirements and guidance relating to appraisal. The Government must rationalise these and develop Integrated Policy Appraisal to become a comprehensive tool. In doing so it must set out how departments should resolve the apparent conflict between monetary and non-monetary approaches to appraising environmental impacts.


7   See paragraphs 11 to 32 of the Annex to this report for our detailed commentary. Back

8   Fourth Report of the EAC Pre-Budget Report 2002, HC 167, 2002-03. Back

9   See paragraphs 25 to 29 of the Annex to this report. Back

10   Second Annual Report of the Green Ministers Committee 2000, Greening Government, DEFRA, Nov 2000, page 29. Back

11   Third Annual Report 2001, Greening Government, DEFRA, November 2001, paragraphs 3.7 to 3.9. Back

12   First Annual Report 2002, Sustainable Development in Government, DEFRA, November 2002, paragraph 2.1. Back

13   Fourth Report from the EAC, Pre-Budget Report 2002, HC 167, 2002-03. Back


 
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