Memorandum submitted by the Council for
the Protection of Rural England
GREENING GOVERNMENT
EXISTING MECHANISMS
15. The remit of the inquiry highlights a number
of the present Greening Government mechanisms. We comment on these
below and make recommendations where we believe they could be
improved before describing how other methods could be used to
complement these mechanisms.
The role of the Cabinet and the Cabinet Committee
on the Environment
16. The degree to which the Cabinet and its
Committees, as the most influential grouping within Government,
consider the environment in their decision making is clearly important
to the progress of the Greening Government initiative. While CPRE
welcomes the fact that the Secretary of State for the DETR is
also the Deputy Prime Minister (and therefore able to wield considerable
"clout"), we are concerned that there is no other Environment
Minister within the Cabinet. It is noticeable, for example, that
following the merger of the DoE and DOT the Transport Minster
was included within the Cabinet, while the Environment Minister
was not. This creates an unbalanced position which does not provide
the right signals for Greening Government. We ask the Committee
to recommend that an Environment Minister be appointed to the
full Cabinet to support the Deputy Prime Minister.
17. The Ministerial Code (1977) is also
relevant to the Greening Government programme. This stipulates
that papers to Cabinet and its Committees must take account of
any significant costs and benefits to the environment. The weight
attached to this, however, in comparison with other impacts is
minimal. For example, paragraph 10 of the Code states:
"Proposals involving expenditure or affecting
general financial policy should be discussed with the Treasury
before being submitted to the Cabinet or a Ministerial Committee.
The result of the discussion together with an estimate of the
cost to the Exchequer . . . should be included, along with an
indication of how the cost should be met".
18. By contrast, with reference to potential
environmental effects the Code simply states that "Memorandum
should also include . . . any significant costs or benefits to
the environment". No reference is made to consulting
the DETR and it is unfortunate that the opportunity presented
by a new Government was not used to improve the guidance or priority
attached to this requirement from that contained in the 1992 copy
of Questions of Procedure for Ministers which the Code
replaced. We recommend that the Committee reviews this code.
19. The establishment of the new Cabinet Committee
on the Environment has the potential to be a positive force for
change. CPRE particularly welcomes the fact that John Prescott
chairs the meetings, since the Ministerial Code makes it
clear that it is for the Chair to decide which issues can be brought
to the attention of the full Cabinet. As Secretary of State, this
provides him with the potential to pursue the Greening Government
agenda vigorously. The workings and priorities of the Committee
are difficult to ascertain outside government and it is difficult,
therefore, to assess its effectiveness in helping to deliver greater
environmental integration.
20. The Government has stated that the remit
of the Cabinet Committee is to "consider environmental
policy issues" (Hansard, HoC 9 June 1997 col 58).
CPRE believes it is important that, in keeping with the Greening
Government initiative, it is clarified that this includes the
environmental implications of other government policies and not
only what might be described as "conventional" environmental
policy. It should be legitimate, in our opinion, for the Cabinet
Committee to examine any area of government policy or practice
that impinges on the environment, such as agricultural support
payments to farmers by MAFF or industrial policy promoted by the
Department of Trade and Industry. We urge the Committee to
press for greater openness in the workings of the Cabinet Committee.
21. In order to build on the existing role of
the Cabinet Committee, CPRE recommends:
— the remit of the Cabinet Committee
on the Environment should be broadened to enable explicit consideration
of the impact of Government policies as a whole on the environment,
not just to review environmental policy;
— a monitoring programme be instituted
by the DETR in conjunction with the Cabinet Office into the effectiveness
of the environmental statements accompanying Cabinet papers, and
proposals published on how the process will be strengthened;
— the Cabinet Committee should be used
to further the Greening Government agenda in addition to the meetings
of Green Ministers;
— the appointment of an Environment
Minister to the Cabinet.
Green Ministers
22. The Greening Government initiative requires
a recognition at all levels of Government that the protection
of the environment is a strategic cross-cutting objective which
needs to be implemented in all areas. In order to further this
objective, however, it is necessary to ensure dedicated Ministers
and senior officials are given specific responsibilities in this
area, and furthermore that they are monitored regularly on progress.
The network of Green Ministers provides a focus to this work.
Historically, however, the Green Ministers have tended to treat
this as a low priority relative to their other responsibilities,
meeting collectively only seven times between 1992 and 1996 (Hansard,
27 November 1996 col 242). This underlines the need for strong
political leadership supporting the work of the Green Ministers.
23. CPRE recognises that greater openness is
now being displayed in the work of the Green Ministers (through,
for example, DETR press releases being issued following each meeting).
This is welcome but still falls short of publishing the minutes
of their meetings.
24. While attention has tended to focus on the
collective meetings of the Green Ministers, the work of the Ministers
within their own department has been poorly reflected in the documents
and policy statements of Government. CPRE welcomes the greater
emphasis which is being given to the role of Green Ministers in
Government policy making rather than just green housekeeping.
It is unclear, however, to what degree the work of the Green Ministers
is actually leading to different policy decisions being made.
25. Without clear procedures to incorporate
the role of Green Ministers in policy formulation, it would appear
difficult, for example, for a junior Minister to intervene in
a decision being made by the Secretary of State. This is particularly
pertinent given that none of the current Green Ministers are Secretaries
of State and the majority are Parliamentary Under Secretaries
of State. Although this has the advantage that Ministers may be
in a position to meet more regularly, it illustrates the need
for complementary measures if they are to have an effective role
in the development of key Government policies. Ensuring links
are made between the work of the Green Ministers and the Cabinet
Committee on the Environment will also be important. We ask
that the Committee examine the work of the Green Ministers and
press for clear procedures and greater openness. We would urge
the Committee to undertake an oral inquiry into the work of the
Green Ministers on an annual basis.
26. In strengthening their role, CPRE recommends
the Green Ministers should:
— set specific departmental targets
for reducing the environmental impact of their departments' policies,
plans, programmes and in-house activities;
— be made more accountable for their
activities through publishing the minutes of their meetings and
any targets which have been set;
— be required to report on progress
in furthering the greening of their department's policies annually
to the Environmental Audit Committee, and in their departments'
annual reports;
— review institutional arrangements
within their departments to facilitate effective environmental
appraisal (see below).
Sustainable Development Unit
27. CPRE welcomes the addition of the Sustainable
Development Unit within DETR, under the leadership of the Deputy
Prime Minister. To function effectively the Unit needs to be well
resourced, given a greater role in "policing" the Greening
Government initiative and have the ability to contribute to policy
development. We are concerned, for example, that the Unit has
made only a limited contribution to the internal debate on the
household projections despite their huge environmental implications.
It is also disappointing that responsibility for the EU draft
Directive on Strategic Environmental Assessment—which provides
one of the key instruments for delivering more sustainable development—is
not held by the Unit. We ask that the Committee investigate
the scope of the Unit's responsibilities and powers and the potential
for broadening them.
28. In ensuring the Sustainable Development
Unit can play a pivotal role in the Greening Government initiative,
CPRE recommends that:
— the Unit is given a specific mandate
by the Deputy Prime Minister to monitor the use and quality of
environmental appraisals produced on an on-going basis across
Whitehall, with the results being published;
— the Unit is invited to review where
changes in Government policy including those of other departments)
might further the objective of promoting environmentally sustainable
development with their recommendations being considered by the
Cabinet Committee on the Environment;
— The DETR ensures sufficient resources
are made available to the Sustainable Development Unit in order
for it to carry out functions appropriate to its aims.
Assessment of Policy Options
29. CPRE believes the procedures adopted for
assessing the environmental implications of policy options are
important within the Greening Government initiative since they
can be applied in all departments and in a wide range of different
situations. However, CPRE's From Rhetoric to Reality 1996
and the Government's own report—Experience with the "Policy
Appraisal and the Environment" initiative 1997—showed
that there is considerable room for improvement.
30. For example, the European Commission has
produced a draft Directive on Strategic Environmental Assessment
(SEA) which seeks to ensure that the environment is considered
in the development of certain public plans and programmes. This
is a formal process which flows from the original Directive on
Environmental Impact Assessment (EIA) (85/337/EEC), and applies
the same structured approach to more strategic decisions as distinct
to individual development proposals. Furthermore, it would allow
for environmental authorities (such as the Environment Agency
or the Countryside Commission) to assist the Government in developing
its plans and programmes, and ensure the public are also consulted.
SEA is a powerful tool for Greening Government and CPRE has urged,
in collaboration with European colleagues, that the Government
supports the draft Directive by placing it on the agenda of the
Environment Council during the UK's Presidency of the EU. The
Deputy Prime Minister, John Prescott MP, in launching the UK Presidency
in January said, "we shall, as Chair of Councils, encourage
the integration of environmental protection requirements into
the Community's policies and activities to promote sustainable
development. . .". We are deeply disappointed to find,
therefore, that the UK will not be prioritising the SEA proposal
during its Presidency. The government is planning a conference
on SEA, although in CPRE's opinion (and, we understand, that of
the European Environment Commissioner) this is not a substitute
for effective legislation. We urge the Committee to press the
Government on why it is not supporting the SEA Directive.
31. The Sustainable Development Unit has prepared
guidance for other departments on environmental appraisal in the
form of an aide-memoire which (combined with technical guidance
notes) is to supersede Policy Appraisal and the Environment.
The original guidance was published in 1991. While it stressed
the need for a systematic approach, monitoring undertaken by CPRE
found that no Government department could provide evidence of
using the guide to assess the environmental impact of their policies
(CPRE 1996).
32. Whilst welcoming the intention to make the
appraisal process more relevant to policy makers, it is essential
that important advice in previous guidance is not lost. In particular,
the draft aide-memoire places heavy emphasis on the role of economists
and monetary valuation techniques in environmental appraisal,
despite evidence that "departments remain averse to such
techniques and they are rarely used" (DETR 1997). Relying
on monetary valuation techniques to quantify environmental impacts
gives rise to serious methodological, intellectual and political
problems. CPRE is concerned, in particular, that it risks giving
insufficient weight to factors which are difficult or impossible
to include in monetary valuation, such as landscape protection.
Furthermore, it may distort policy formulation by wrapping up
political and subjective values in a highly aggregated figure
which fails to reflect the many ways in which environmental assets
are valued.
33. We are also concerned that very important
decisions are being made by government departments (over the Comprehensive
Spending Review, for example) before the aide-memoire has been
circulated. We believe that in order to overcome the problems
caused by an overly quantitative approach using monetary evaluation,
and the need for guidance to be in operation now, the Deputy Prime
Minister should clearly state that all government policies, plans
and programmes should be accompanied by an environmental appraisal
using the guidance contained in Policy Appraisal and the Environment;
that the aide-memoire is in addition to existing guidance; and
that the appraisals should be made publicly available. In order
to build on the existing guidance we believe Policy Appraisal
and the Environment should be improved and explicit reference
made to the role which environmental targets and indicators should
play in the assessment of policy options.
34. Not only does the environmental appraisal
process need to occur and become more transparent, it also needs
to be an integral part of the policy making process. The experience
of Policy Appraisal and the Environment indicates that
its production and dissemination was insufficient to reap real
changes in government policy. In comparison, procedures established
to promote other pan-government objectives, such as competitiveness,
involved guidance on how to produce a cost compliance assessment
(which examines the cost to business of implementing the measure)
as well as an array of other mechanisms which promoted the objective
across Government, including creating specific units, staff training
and establishing practices to monitor progress. These measures
worked to reinforce each other and combined with strong political
support to generate a strong momentum behind the initiative. We
make a number of suggestions below on how this could be done in
relation to environmental appraisal. We urge the Committee
to ask Ministers how Greening Government will be pursued with
the vigour that has occurred to promote other pan-Government objectives
in the past.
35. In improving the existing arrangements for
assessing the impacts of policy options, CPRE recommends:
— the Government should place the discussion
of the EU draft Directive on Strategic Environmental Assessment
on the agenda of the Environment Council, and support it as a
priority measure during its six month Presidency so as to establish
a formal and robust procedure for assessing the effects of plans
and programmes;
— the aide-moire should be provided
to civil Servants as an addition to, rather than substitute for,
Policy Appraisal and the Environment;
— Policy Appraisal and te Environment
should be improved and explicit reference made to the role which
environmental targets and indicators should play in the assessment
of policy options;
— all environmental appraisals should
be made available to the Environmental Audit Committee and the
public in the spirit of greater openness;
— the Deputy Prime Minister should
clarify that all Government policies, plans and programmes
should be subject to an initial environmental appraisal to identify
whether significant environmental effects might occur;
— Government departments establish
procedures to enable the Environmental Audit Committee and members
of the public to know when a department believes a full environmental
appraisal is not necessary;
— all Ministers be required to certify
that they have considered the findings of the environmental appraisal
and believe their decision is compatible with the promotion of
environmentally sustainable development, and for these certificates
to be made publicly available when the decision is announced.
Training
36. In order to ensure greater awareness of
the need for environmental integration and the benefits which
can accrue, CPRE believes it is important to put in place a training
programme in order to reinforce other Greening Government mechanisms.
It is noticeable that the Private Finance Initiative hoped to
train between 5,000 and 10,000 civil servants in the workings
of the PFI (HC Hansard 27 June 1996). In comparison the
number of civil servants trained in the use of Policy Appraisal
and the Environment was approximately 341 (HC Hansard 11
July 1997).
37. CPRE recommends that the DETR should establish
a comprehensive training programme on environmental appraisal
for civil servants at all levels of policy development and in
Government Regional Offices, Next Steps Agencies and Non Departmental
Public Bodies.
Reporting on Sustainable Development Issues
38. Ensuring that the Government is able effectively
to explain its environmental performance (including progress in
the mechanisms to "green" itself) is important for monitoring
purposes. It also provides a mechanism to generate continued momentum
for action within government department. CPRE believes the Environmental
Audit Committee will play a particularly important role in this
respect. The reporting mechanisms should not be confined to the
Environmental Audit Committee, however. Since the publication
of the Environment White Paper in 1990, This Common Inheritance,
the Annual Reports of each department have been used, to varying
effect, to describe how the environment has been considered and
specific White Paper commitments met. Reviews of departments'
annual reports by both CPRE and the Green Alliance have shown
that these often fail to incorporate important information. Problems
frequently identified included failing to describe how cross-cutting
issues have been addressed by the department and the work of the
department's Green Minister. It is also worrying, for example,
that the Annual Reports of at least seven government departments
(including notably the Cabinet Office and the Treasury) failed
to mention the environment in their aims and objectives (Green
Alliance 1997). In our view, there is considerable room for
improvement and given the important status which is attached to
these documents both within government and externally, we believe
there should be a renewed impetus to ensure sufficient space and
attention is paid to this objective in annual reports.
39. More could also be done to ensure the House
of Commons Select Committees scrutinise the environmental content
of departmental annual reports and progress in meeting environmental
objectives. We ask the Committee to inquire what advice has
been given to departments regarding the environmental content
of annual reports, and for the Committee to liaise with the Select
Committee's of the House of Commons to ensure Government departments
are questioned on the environmental content of their Annual Reports.
40. To assist the development of reporting procedures,
CPRE recommends that Annual Reports should include:
— an explanation of how cross-cutting
objectives (such as promoting environmentally sustainable development)
have been addressed;
— trends of those indicators for sustainable
development which relate most directly to the Department's policies,
and performance in meeting any environmental targets that have
been set;
— a description of the work the Green
Minister has undertaken in the previous year to demonstrate that
environmental considerations are systematically considered in
the work of the department, and a list of the environmental appraisals
undertaken by the Department during the year.
41. CPRE also recommends that Select committees
should address questions relating to departmental performance
on environmental objectives during their regular examination of
Ministers, and the Environmental Audit Committee should inquire
into the departmental Annual Reports each year.
OTHER
MECHANISMS
Comprehensive Spending Review (CSR)
42. The current Comprehensive Spending Review
(CSR) provides a perfect opportunity to integrate the objectives
of environmentally sustainable development into the mission statements,
policies and detailed workings of Government departments. Each
department has been asked to justify why each area of activity
it undertakes is necessary to meet Government objectives. In CPRE's
eyes, this means that departments should need to explain how each
aspect of its work is contributing to the promotion of pan-Government
objectives including environmentally sustainable development.
It is rare for all departments to be required to review their
own workings in such a comprehensive manner and the opportunity
should not be lost to use this to further environmental objectives.
43. Linking environmental performance with budgetary
constraints would provide a significant incentive to government
departments to scrutinise the effect of their policies on the
environment. It is, therefore, very disappointing that sustainable
development was omitted from the published terms of reference
of all but one review (that of the DETR). We urge the Committee
to ask Ministers how environmentally sustainable development will
be reflected in the outcomes of the CSR.
44. CPRE recommends that:
— the Deputy Prime Minister be encouraged
to confirm that the promotion of environmentally sustainable development
is a central and overarching theme of the CSR and that it will
need to be reflected in the findings of each review;
— all departments should review their
mission statements, aims, objectives, internal structures and
public expenditure programmes to see if they are capable of addressing,
and are compatible with, the cross-cutting issue of environmentally
sustainable development.
UK Round Table on Sustainable Development
45. The UK Round Table on Sustainable Development
was established to provide a forum where a consensus could be
reached between different "stakeholders" on a wide variety
of issues which have implications for sustainable development.
The Round Table exists, amongst other things, to inform government
and has made a series of recommendations. CPRE welcomes the decision
by the Government to maintain the Round Table and that the Deputy
Prime Minister has agreed to become its President. It is not clear,
though, how much priority is being given to the work of the Round
Table. This is highlighted by the failure of the Government to
respond to the detailed recommendations of the Round Table's reports
on Housing and Urban Capacity, Freshwater, and Getting Around
Town all published in February 1997.
46. In improving the effectiveness of the Sustainable
Development Round Table, CPRE recommends that the:
— Government should be asked to undertake
to respond individually to each of the Round Table's individual
reports and outline what action is proposed against each of the
recommendations made within them;
— Government gives priority to the
work of the Round Table by ensuring, for example, regular ministerial
attendance at its plenary meetings;
— Government increase the level of
resources available to support an independent Secretariat for
the Round Table.
Restructuring of Government Departments
47. CPRE is aware of discussions within the
Ministry of Agriculture, Fisheries and Food (MAFF) concerning
its future areas of responsibility and structure. The outcome
of these deliberations has a direct bearing on the countryside
which itself is a cross-cutting policy issue. The quality and
character of rural areas is heavily influenced by the policies
of many different Government departments and divisions within
individual departments. As such it is important that the right
connections are made within government.
48. CPRE is concerned that the existing countryside
protection responsibilities of the DETR may be transferred to
a new Department of Rural Affairs. Although perhaps attractive
at first sight, we have grave reservations over how the countryside
would be treated across Government as a consequence. There are
distinct advantages to having responsibilities for countryside
protection located within the DETR. This ensures important links
can be made between the countryside, planning, housing and transport
policies. Furthermore, a new Department of Rural Affairs is likely
to be relatively small and have problems with its "poacher/gamekeeper"
role viz a vie agricultural production and countryside protection.
In CPRE's view this risks creating a parochial department which
is effectively marginalised and which would institutionalise a
divide between town and country when other policy developments
are pushing things in the other direction. Parallels can be drawn
with the treatment of Heritage issues following the creation of
the Department of National Heritage (now Department of Culture,
Media and Sport). An alternative would be to strengthen the countryside
role of DETR and produce new overarching objectives for MAFF based
more on the needs of the environment and consumers. MAFF could
be integrated into the Government Regional Office structure and
have a new relationship with the Countryside Agencies.
49. CPRE wishes to highlight the significant
impact which current discussions over the future structure of
MAFF could have on countryside protection and recommends that
the Government drop plans to create a new Department of Rural
Affairs. We urge the Committee to support this case.
Sustainable Development Strategy
50. CPRE looks forward to the launch of the
consultation on the draft Sustainable Development Strategy. This
will provide an important opportunity to take stock of progress
and to consider how the threats currently facing the countryside
and wider environment can be overcome, and opportunities grasped
for positive enhancement. One of the most important tasks of the
Strategy should be to set overarching objectives which provide
a common goal to which all departments and arms of government
can operate. This should be undertaken in a transparent and participatory
manner and include new proposals for strengthening the Greening
Government initiative so that the strategy's objectives may more
readily be achieved. CPRE believes this would usefully be assisted
by the establishment of a national resource management strategy
with national targets, for example, for reducing road traffic
levels, waste generation and the consumption of energy, minerals,
land and water resources. We ask the Committee to support the
need for a national resource management strategy.
51. CPRE recommends that:
— the Government is encouraged to use
the Sustainable Development Strategy to examine the myriad of
pressures facing the environment, from climate change and loss
of bio-diversity, to increased urbanisation, rising traffic levels,
and the over consumption of natural resources;
— the Government is encouraged to commit
itself to producing a national resource management strategy which
contains targets and programmes for reducing the consumption of
natural resources in the UK and traffic levels.
Indicators of Sustainable Development
52. CPRE welcomes the active debate which is
now taking place at national and local levels regarding the use
of environmental and sustainable development indicators. The Governments
intention to produce a set of headline indicators for wide dissemination
is particularly encouraging. These should be helpful in monitoring
progress in meeting environmental objectives. In so doing they
need to encompass those aspects of the environment which are less
quantifiable, but which none the less are highly valued by the
public—such as the availability of tranquil areas in the
countryside. CPRE views the development and use of indicators
as an important aspect of the Greening Government initiative.
As such, we believe there is a much stronger role for their use
in helping to inform government departments of likely environmental
effects during policy formulation, a point reinforced by a report
by the UK Round Table on Sustainable Development (SDRT 1997).
We have made a number of recommendations elsewhere in this submission
on how this might be achieved. We urge the Committee to explore
with the Government the type of indicators which they are looking
at and to stress the importance of indicators in relation to those
aspects of the environment which are less easy to quantify (such
as the quality of landscapes). More strategically, we recommend
that:
— the Government publish a set of publicly
resonant environmental indicators to encourage and monitor change
and introduce new measures of progress which address quality of
life and environmental concerns, moving beyond conventional measures
of economic progress.
Legislation
53. Environmental duties have been included
in a variety of Acts in order to ensure that Ministers and public
bodies consider the environment in carrying out their particular
functions. We believe that all new legislative proposals which
are brought to Parliament should be accompanied by an environmental
appraisal since they are an extension of Government policy. Experience
to date has shown, however, that it can be difficult when Parliamentary
time is so limited, for sufficient attention to be paid to the
environmental consequences of a Bill. As such, CPRE believes the
Greening Government initiative should be underpinned by new legislation
which sets out clear environmental duties.
54. CPRE recommends new legislation is brought
forward which places a duty on all Government Departments and
public bodies to further the conservation and enhancement of the
environment and of natural resources by integrating environmental
considerations into the preparation of policy and the discharge
of all their functions. This should require a review of potential
conflicts which might exist in the current priorities of government
and public bodies (such as the differing duties of utility regulators).
The Budget
55. The need for economic and environmental
policies to be compatible is a key factor given the dominance
of financial considerations in the workings of Government and
agencies. CPRE welcomes the Government's stated intention to look
at the role economic instruments can play in encouraging more
sustainable and resource efficient forms of development. We also
see an important role for the development and introduction of
"green accounting" mechanisms. These adopt a broader
approach in defining progress by including aspects of the environment
which are not included in conventional financial accounting or
GDP, such as environmental pollution. Green Accounts can, therefore,
help to integrate concern for the environment with financial policy.
56. CPRE recommends that the Government should
introduce a number of new economic instruments to further environmental
objectives, including a greenfield levy; harmonisation of VAT
on new build and conversions; and charges on private non-residential
parking.
57. The budget announcement should also be accompanied
by a statement on "Green Accounting" which describes
the state of the economy using broader definitions of economic
growth and quality of life. This should also demonstrate how the
decisions contained within the Budget will impact on these new
measures of progress.
CONCLUSIONS
58. CPRE warmly welcomes the Government's commitment
to Greening Government and believes that, if implemented successfully,
it will reap many benefits. Our submission has illustrated that,
while some mechanisms are in place, they have not been particularly
successful in changing the course of government policy towards
a more environmentally sustainable approach. We have made a number
of constructive suggestions for how existing mechanisms can be
improved, and new measures developed, to help ensure the Government's
commitment becomes a reality.
Key references
Cabinet Office (1997) Ministerial Code: A
code of conduct and guidance on procedures for Ministers.
CPRE (1996) From Rhetoric to Reality.
CPRE (1997) Greening Government—A Review
of the Annual Reports of certain Government Departments.
CPRE (1997) Comprehensive Spending Review—A
CPRE Submission.
DETR (1997) Experience with the "Policy
Appraisal and the Environment" Initiative.
Green Alliance (1997) Greening Government
Reporting.
Round Table on Sustainable Development (1997)
Getting the Best Out of Indicators.
January 1998
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