3. ENVIRONMENTAL
APPRAISAL OF
POLICIES
In 1991 the Department of the Environment published
Policy Appraisal and the Environment to offer a systematic
approach to the treatment of environmental issues within policy
appraisal. In 1996 KPMG were commissioned to evaluate the impact
of the guidance on decision-making across central Government.
This was published by the Labour Government together with a statement
on how it intended to address the shortcomings identified[4].
To The Green Alliance the key issues fall into six categories.
Accessibility and training for officials
Our own analysis, based on contact with officials
between 1994 and 1996, revealed that the guidance had been little
used. Reasons included: lack of expertise to employ the quite
complex appraisal methodologies; a view that the formal means
of appraisal suggested were not always appropriate; lack of promotion
and training; and a view that the guidance was not user-friendly.
We welcome the fact that the Government is producing
an aide-memoire to set out the steps involved in incorporating
environmental considerations into policy appraisals (see next
point for further comment). The Government also intends to provide
more technical guidance on how best to incorporate the appraisal
of environmental impacts into the overall appraisal of policy
(together these will replace Policy Appraisal and the Environment).
We believe every effort should be made to develop appraisal methodologies
that allow side-by-side consideration of economic and qualitative
environmental factors, whether or not the latter can be converted
into monetary values. Greater emphasis on qualitative consideration
of environmental factors should help to make methodologies more
accessible and user-friendly for officials.
So far announcements made by Green Ministers
have not addressed training. We believe training should be
provided by the Civil Service Training College as well as by individual
departments and DETR.
Applicability
Environmental appraisals are most likely to
be conducted where there are clear and significant potential environmental
impacts. Where this is not the case officials may regard an environmental
appraisal as unnecessary. We therefore believe that the aide-memoire
should point out that it should be assumed that every policy has
environmental implications until an initial scoping exercise
has been able to show otherwise. This would ensure that the aide-memoire
is followed in every case, as well as at an early stage, and not
simply when considered appropriate.
Aims and objectives of policies and programmes
KPMG found that some appraisals did not involve
a fundamental reassessment of policy or programme objectives.
In some cases there were real and binding constraints—for
instance officials may not have been able to revisit high-level
objectives set by Ministers. We believe that all policy and
programme aims should reflect the Government's desire to pursue
sustainable development. If this were the case there should,
as a matter of course, be more formal consideration of environmental
impacts at the objective-setting stage. In addition this might
serve to increase the scope for objectives to be questioned in
the light of environmental implications identified during the
course of an appraisal.
Monitoring
We welcome the fact that Green Ministers have
agreed to undertake regular collective reviews of the quality
and scope of appraisals. Green Ministers must select a balanced
cross section of appraisals to be reviewed—a favourable
selection of case studies will fail to elucidate particular difficulties
that may be being experienced in conducting appraisals, as well
as cases where environmental considerations have been given inadequate
attention. Only a "warts and all" approach will enable
Green Ministers to identify difficulties and shortcomings and
decide how they might best be addressed.
KPMG recommended that Green Ministers should
take collective responsibility for ensuring that Departments have
the necessary systems and processes in place to ensure environmental
issues are effectively dealt with. Green Ministers have not yet
announced how they intend to address this recommendation. It might
be possible to incorporate this into departmental environmental
management systems.
We believe that KPMG's evaluation of the policy
appraisal process was a valuable exercise. We recommend that
DETR should commission and publish a similar independent exercise
in future. There should, however, be more emphasis on (a)
identifying difficulties being experienced in conducting appraisals,
and (b) examining the extent to which environmental appraisals
are being conducted across Government, even if these are on a
non-attributed basis.
Transparency for decision-makers
Some appraisal techniques espoused by the guidance
and KPMG involve placing monetary values on environmental, as
well as other, costs and benefits. Given that no appraisal technique
is free of subjectivity or value judgments, what is important
is that techniques are transparent and accessible to decision-makers.
We are concerned that monetary valuation techniques hide uncertainties
and assumptions in complex calculations that are accessible only
to the economist. We believe that the Government should give
far greater emphasis to developing techniques that are transparent
and accessible.
Openness with Parliament and the public
To date it has been difficult for outside commentators
to judge how effectively techniques laid out in Policy Appraisal
and the Environment are being applied within Government. We
believe that in order to be a) accountable to the public, and
b) to draw upon expertise outside of Government in a constructive
way (as KPMG suggested), policy appraisal documents, or detailed
synopses, should be made publicly available by Departments on
a routine basis. In addition we believe that officials,
as well as Green Ministers, should be answerable to the Parliamentary
Environmental Audit Committee on how environmental considerations
have been taken into account in policy appraisal.
4. REPORTING
ON SUSTAINABLE
DEVELOPMENT ISSUES
BY DEPARTMENTS
The Environment White Paper, published in 1990,
suggested all Government Departments convey activity and progress
relevant to the environment in their annual reports. The First
Anniversary Report to the White Paper carried a specific requirement
for departments to account for their environmental performance
in their annual reports or elsewhere. The Green Alliance has analysed
environmental reporting in annual reports published in 1991, 1992
and 1997[5].
So far the Government has not publicly stated
that it intends Departmental Annual Reports to continue to reflect
on environmental considerations. We believe that Annual Reports
provide a particularly good vehicle for discussing ways in which
Departments are integrating environmental and wider sustainable
development considerations into policy-making and implementation.
We therefore strongly recommend that there continues to be
a requirement for Annual Reports to outline environmental progress.
To The Green Alliance the key issues fall into
five categories.
Integration and sustainable development
Reports tend to incorporate a limited discussion
of how departments interpret and pursue the principles of sustainable
development. As well as reporting on this, far greater emphasis
needs to be given to discussing ways in which departments seek
to integrate environmental considerations into other policy areas.
Aims and Objectives
In 1997 just under half of the Departments mentioned
the environment or sustainable development in overall departmental
aims and objectives. Furthermore, environmental considerations
were not always reflected in the aims and objectives of relevant
policy directorates. Some departments whose policies have a clear
bearing on the environment failed to refer to the environment
or sustainable development in any aims or objectives. It
was not always evident that environmental aims were being taken
into account in pursuance of other policy aims.
We believe that all departments should develop
cross-cutting strategic aims that reflect Government-wide commitments
to pursue sustainable development and to protect and enhance the
environment. Reports should reflect on how these are being
addressed in pursuance of all policy aims. In addition,
all departments whose policies have a clear bearing on the environment
should reflect a full appreciation of this in their articulation
of overall aims and objectives, as well as those of appropriate
directorates.
Green Ministers
In 1997 only one department provided a breakdown
of its Green Minister's key activities over the previous year.
A summary of Green Minister's activities should be included
in all Departmental Annual Reports.
Green Housekeeping
In 1997 only six departments quantified their
performance against government-wide energy efficiency targets.
No Annual Reports quantified performance against other "green
housekeeping" targets. Reports should set out and quantitatively
report against a far more comprehensive set of targets.
DETR guidelines
We believe that DETR should develop guidelines
for departmental environmental reporting.
5. QUESTIONS
OF PROCEDURE
FOR MINISTERS
Guidance issued under the previous administration,
Questions of Procedure for Ministers, made it clear that
papers for Cabinet and Ministerial committees should, wherever
appropriate, cover any "significant" costs and benefits
to the environment. We understand that this guidance is still
in place, but that the absence of criteria for what constitutes
a "significant" environmental cost or benefit has made
it difficult to evaluate the success of this mechanism. We believe
that there would be merit in reviewing the effectiveness of this
guidance, perhaps after the first year of its operation under
the new administration. In addition, while accepting the difficulties
of releasing Cabinet papers, we believe some effort should be
made to demonstrate publicly that the procedures are being followed.
6. CONCLUSION
We think that there have been important advances
taken in integrating environment considerations into decision-making
across Government. We welcome the initiatives taken by the last
administration and the attempts to build on these by the current
Government.
The Green Alliance believes that, as outlined
above, a number of steps need to be taken to reinforce progress
that has already been made. We also believe that the Environmental
Audit Committee will have a crucial role to play in helping to
place existing measures on a stronger footing.
Now that progress has been made at the central
Government level, we must also ensure that these measures move
beyond Whitehall and inform practice in all the new structures
of Government currently being set up—the new Greater London
Authority and the Regional Development Agencies being just two
examples.
January 1998
1 This Common Inheritance, Britain's Environment Strategy,
HMSO, 1990, Cm 1200, pp. 230. Back
2
Ibid. Back
3
DETR press release 315/ENV, 31 July 1997.
<lh.5>
The cost of printing these Minutes of
Evidence is estimated by The Stationery Office at £650. Back
4
The November 1997 issue of The Green Alliance's Greening Government
Monitor has a detailed article setting out our recommendations
in response to these. Back
5
The 1997 study, Greening Government Reporting, makes comparisons
with practice in 1991 and 1992. Back
