Examination of witnesses (Questions 780
- 799)
TUESDAY 19 MAY 1998
MR PETER
MADDEN, MS
JULIE HILL
and MS INGRID
MARSHALL
780. Various groups have been set up, the
Round Table, the Local Government Group. Do you think we have
got the right group setup for 1998 or the new millennium or would
you reorientate these groups and start afresh?
(Ms Hill) I think it would be very valuable to
do an assessment of what they have achieved and how successful
they have been. I think it is fair to say that a lot of these
groups were quite innovative when they were set up and they were
in a sense experimental, to see whether you could get good ideas
and agreement out of cross sectoral groupings in a semi formal
structure within Government, and I think this amount of time on
it would be valuable to assess those and have a picture of what
they have achieved. Some may be very valuable engines of change
and others may be less valuable. I am sure one could always think
of different groupings as the policy priorities change. Also perhaps
you need more high level groupings. Again carbon dioxide and energy
policy is going to be one a policy area where an awful lot has
been said and still on the ground there seems to be comparatively
little real change either in terms of more energy efficiency or
renewals commitment or a different vision for energy. One could
validly question whether the right people are being brought together
on that front.
781. If I could move on now to environmental
appraisal. Environmental management systems are in place in many
organisations but in central government environmental management
systems seem to be almost a no-go area and the cost seems to be
an important factor. Is that your impression?
(Ms Hill) Yes. My impression of environmental
management systems from the business side is that they are a big
paper chase. They are immensely valuable and they are a very strong
discipline but to get one in place involves a lot of in-house
and out-of-house effort to get all the right paper trails assembled.
I can see why government departments would be resistant to that
especially, as they already largely have their own quite detailed
reporting and accountability mechanisms for expenditure. I imagine
the question in their minds would be how on earth you would enmesh
this environmental accountability paper chase with the ones they
already have to do for general public accountability of their
spending. Having said that, I think if it could be achieved they
are a very good discipline. The lesson of environmental management
systems for business has been that they require attention to both
direct and indirect environmental effects—so downstream
environmental effects and things that may not be immediately obvious.
That becomes very relevant when you are talking about a department's
policy responsibility. It is all very well having a management
system that deals with your paper and energy use but there is
not much point in having it unless it extends into the department's
policy responsibility and whether that in a direct or indirect
sense is having some impact on the environment. I can see the
value in having them but I think we would be hesitant to absolutely
prescribe them for the reason that that may well be impracticable
at least in the short term. What we have often said for companies
is that they should have five-year goals to work towards a formal
environmental management system.
782. Does the new policy guidance "Policy
appraisal and the environment" meet your concerns regarding
accessibility of guidance, applicability and transparency and,
above all, do you think other officials will now be encouraged
to consider the environment in their policy appraisal work?
(Ms Hill) It is better than it was in the sense
that it is briefer and clearer and certainly more accessible about
what is required than the rather long documents produced by the
last administration. I think in the last resort it does not guarantee
anything. What will guarantee good policy appraisal outcome is
the willingness on the part of departments to do the thinking.
So no amount of checklists will actually create that intellectual
ownership or psychological ownership, if you like, on the importance
of the issues. I think the new guidance shares the slight schizophrenia
of the old documents between the extent to which you can turn
environmental impact into monetary costs and weigh them up in
that way and the extent to which a lot of them may well be unquantifiable
in monetary terms and simply have to be written down as policy
considerations to be considered alongside those impacts that can
be turned into monetary costs. I think there is still some unclear
language about costs and benefits and whether these are monetary
costs and benefits or not.
Chairman
783. Do not you think that is a general
problem that has not been adequately resolved by environmentalists?
(Ms Hill) Indeed and I think it reflects the difference
between the Treasury, who in methodological terms would like to
see as much as possible reduced to monetary evaluation for perfectly
sound reasons of public accountability, and those who feel it
is illegitimate to reduce certain environmental considerations
to mere figures.
784. Where do you see the debate on methodologies
and getting proper evaluation of costs and benefits at the moment?
(Ms Hill) We are still waiting for further guidance
on the monetary evaluation techniques which we understand is being
drafted by Professor Pearce so we await with interest to see what
kind of methodologies are favoured.
Mr Dafis
785. You know about the Pearce approach.
Are you happy about it? Unhappy? Mixed feelings?
(Ms Hill) We feel the emphasis on contingent evaluation
is often mis-placed and that there are instances where contingent
evaluation has been applied where it is just not legitimate or
useful or helpful to do so.
Chairman
786. Have you had any more recent examples
of where environmental appraisal has been tried? A lot of the
information we have been glad to have from you and others has
been rather elderly. Have you had any recent information where
they have used a particular technique?
(Ms Hill) No, we have not have any published examples
of use of the techniques. I slightly suspect there are none.
787. We had this famous memorandum from
one of your member organisations more or less indicating that
the last Government had not done anything. There were no clear
examples.
(Ms Hill) They have not published any. There were
lots of sets of case studies. Many of those were actually environmental
appraisals of specific projects designed to underpin policies.
The KPMG report gives you a sense of the kind of thing that was
done. Again, those were self-selected examples put forward to
KPMG by the departments. It was not an analysis of penetration
of policy appraisal. We still do not have that analysis.
788. We have had the new Government for
a year now. Would you have expected any policy appraisals yet?
(Ms Hill) I think Peter's example of the regional
policy is probably one of the key ones.
(Mr Madden) Yes, and there is also the process
whereby the guidance was being rewritten and people were almost
being told, "Wait for the new document and then all will
become clear and easy and transparent".
789. So when would it be reasonable to expect
these to appear, do you think?
(Ms Hill) I am not sure it was reasonable for
people to argue that they were waiting for new guidance because
in fact the new guidance is almost a summary of the old guidance
and the ideas are fairly self-evident in a way, so we should be
seeing them coming through now, at the moment. Your own scrutiny
of the Budget exercise was a very good example where clearly the
thinking is just not penetrating uniformly.
790. There was some criticism by someone
from one of the groups which came to the Committee that the sort
of checklist approach of environmental appraisal was rather out
of date, that if you simply go through a procedure whereby you
say at the end of it, "and the environmental consequences
will be X", he described this as hanging baubles on to policies
and that it ought to be far more internalised than that. Do you
have a view about that?
(Ms Hill) Well, I think if what is meant by internalisation
is that at the very early stage of policy formation, it is in
people's minds what the environmental consequences might be and
the major impacts and that is reflected all the way along, then
yes, I certainly agree with that. I think that comment might be
directed to the stage at which the checklist is applied. I think
it is a reasonable checklist and they are the kind of things everyone
should have in mind and ideally they would be in people's minds
and you would not have to look at them on a piece of paper, but
I think the hanging baubles comes in if you do it at the very
last stage of policy development and make a note of what those
things are and there is no iteration to read back the supposed
environmental impact to change the policy, but if the checklist
is something that takes place almost intuitively at the very early
stages, I do not see why it should not be useful.
791. Do you have any evidence from any other
European countries on this issue?
(Ms Hill) Well, the Netherlands have some interesting
approaches which Ingrid will describe.
(Ms Marshall) The Netherlands have got a major
push on looking at the business and environmental side-effects,
as they call them, of draft legislation and there are some interesting
things going on there. The Economic Affairs Ministry and the Environment
Ministry have got together and they have this support centre which
helps the departments to consider what the side-effects may be
of draft legislation. They provide training, seminars and they
have databases to help in the identification of these environmental
and business side-effects. They have a checklist as well which
is very simple for the environmental side, it is just four questions
that they would like to be put and clarified, such as whether
it affects energy or transportation, whether it affects the consumption
of materials and available physical space, as well as pollution
and emissions. So it is really quite a simple approach and they
provide guidance and assistance.
792. So this is their Economics Affairs
Ministry, did you say?
(Ms Marshall) Yes, together with the Environment
Ministry and there is a separate checklist for the effects on
business as well, so basically they help the ministries to consider
both types of effects of draft legislation. What is also interesting
is that there is an inter-departmental group which looks at new
pieces of legislation that are emerging and identifies those ones
in particular that it wants to address, say, the transport question
in the environment checklist, and that then goes to the Council
of Ministers for their agreement. So from the highest level there
is a direction for draft legislation to look very carefully at
particular side-effects, so it comes from a very high level.
Mr Dafis
793. What is the mechanism that could do
that here? Would it be ENV?
(Ms Marshall) Well, we think that the Sustainable
Development Unit could perhaps play a similar role to the support
centre on the environmental effects and perhaps the Green Ministers'
Committee and ENV could provide the high-level direction for,
"You must look at X implications of a particular piece of
draft legislation".
(Ms Hill) But this only applies to legislation,
whereas we want to make sure that this process works with policy
initiatives more broadly.
Dr Iddon
794. Could I say that Mr Meacher did not
see any reason why environmental appraisal work of the different
departments should not be recorded and eventually reported, which
I am sure this Committee would approve of. Have you attempted
to examine any policy appraisal work recently of any of the departments
and, if so, have you been able to?
(Ms Hill) We have not had specific access to any,
no. I think it is very important that they are published and they
are published in some reasonably uniform format. I think that
would in itself provide a certain discipline.
Chairman
795. Coming back to this question of how
internalised the whole business of environmental appraisal was
and the way it was presented, I think the danger is that if you
have a policy and you then have a checklist for costs, effect
on women, effect on equity, effect on the environment, you are
forcing officials to go through a system which is not looking
at the thing in a fundamentally sustainable development way, but
you are just simply having a checklist at the end of the policy.
(Ms Hill) Yes.
796. Is this not a difficulty and how do
you overcome it?
(Ms Hill) Well, it is a difficulty which is why
we emphasised at the beginning that there are two roles for Green
Ministers. There needs to be some way of developing and underpinning
the sustainable development strategy which, in our view, is the
place where you do the much more proactive thinking about what
different kinds of policies are required, or major policy changes,
or major sectoral changes, to meet a goal of sustainable development,
which hopefully will then feed back into the policy-making process.
At the same time as that is happening you want to ensure that
policies coming forward under what we might term a "business
as usual" scenario are still being screened for their environmental
implications.
797. So there are two types of policy, as
it were, the ones which are coming forward anyway and the ones
which are actually proactively recognising sustainable development.
(Ms Hill) Well, hopefully that will be our future,
that all policies will proactively recognise sustainable development.
At the moment they do not.
Mr Grieve
798. So your anxiety is that whilst we are
busy setting up these systems, we should not lose sight of the
fact that government is going on.
(Ms Hill) Yes, exactly, government does go on
and there are different political priorities at different times
and this is why we can put a lot of emphasis on process, but in
the end there will not be real policy change without the political
will to do that. That is the primary driver. However, once the
political will is in place and there is an effort to do things
differently in departments, you still need the processes, you
need the monitoring, you need the training and people's awareness
to underpin that. I think one without the other will not work.
There is no point in having a strong political push if there is
not the expertise and administrative processes to ensure that
that translates into good policy and there is no point having
endless administrative processes without any political momentum
behind them, so neither is going to solve the problem on its own.
Chairman
799. Just while we are on the subject of
political momentum, what do you think of this idea which Mr Meacher
seems to be floating of having a very small number of highly visible
targets and indicators? I think this is an attempt to get away
from the 120.
(Ms Hill) That is a very good idea.
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