House of Commons - Environmental Audit

Select Committee on Environmental Audit Fifth Report

THE GREENING GOVERNMENT INITIATIVE:

FIRST ANNUAL REPORT FROM THE GREEN MINISTERS COMMITTEE

Environmental appraisal of policies

28. In our second report on the Greening Government Initiative, and again in our report on the Comprehensive Spending Review, we expressed our concern over the lack of evidence of significant progress with respect to the conduct of environmental appraisal.[33] The Green Ministers report contains a section on environmental appraisal which sets out steps being taken to monitor and develop the initiative as well as a summary of the approaches taken by individual departments.[34] The report sets out a list of mechanisms departments use to ensure that environmental appraisal is properly undertaken. From the summary of approaches by individual departments it appears that not all these steps are employed by all concerned. From this summary list we have generated the following table to illustrate what we regard to be a more useful approach to setting out progress—that is, defining common standards and assessing departmental performance against them.

(1) The table is based on departments' summary statements in Table 3.2 of the GMCR 1998/99 as against a set of steps identified by the Committee. Steps explicitly undertaken are marked by crosshatching - steps implied by specific undertakings are indicated by single lines.

(2) This refers to the existence of a standing requirement. We note below the specific published appraisals identified by Green Ministers.

(3) These departments also refer to work undertaken to advance the initiative across government as a whole.

We do not regard the approach adopted in the Green Ministers' report to demonstrating progress on environmental appraisal to be an adequate response to the effort we called for in our second Greening Government report.[35]

(i) Scope

29. The section starts by asserting that all departments will have at least some policies which impact on the environment and, later on, states clearly that the requirement to consider environmental costs and benefits of policies means:

"that all new policy proposals have to be screened for environmental impacts. Where the initial screening suggests that the impacts are likely to be significant, departments then undertake an environmental impact appraisal based on the procedures set out in DETR's Policy Appraisal and the Environment note".[

We support making an effort to direct finite resources to where they will yield the most return. A blanket requirement to fully appraise the environmental impacts of any and all policies would be pointless and bring the initiative into disrepute. It does seem right however, that a screening process is adopted by all departments so as to prevent potentially significant impacts slipping through the net. The Green Ministers Committee has already produced a user-friendly guide to environmental appraisal—perhaps it should now produce a model policy and guide on screening proposals for potential environmental impact including the practical steps to take and thresholds for triggering full appraisal.

30. The report also states that decisions on publication of environmental appraisals are for each department to take. We were disappointed to see that only the Department for Education and Employment is explicitly committed to systematic publication of the results of screening and appraisal of all policy proposals for environmental impacts. We were particularly surprised that the Department of the Environment, Transport and the Regions, in leading the initiative on environmental appraisal, does not make a similar commitment. We note that even the DfEE's commitment appeared to be inconsistent as elsewhere in the report that department states that it is set to screen only "a number" of forthcoming policies for significant environmental impact.[37]

(ii) Options appraisal versus impact assessment

31. We believe that the Green Ministers report marks something of a retreat from the Government's original commitments on environmental appraisal of policy. Policy Appraisal and the Environment was rightly concerned with integrating environmental issues into the appraisal of options for achieving the policy objectives, ie right from the start. The guidance seeks to set out practical steps for comparing the relative environmental impacts of different options. This accords with the Prime Minister's UN statement, quoted above[38], that 'environmental considerations must be integrated into all decisions at the start not bolted on later'.

32. We see indications in this report that the Government is blurring the distinction between 'options appraisal' and 'impact assessment' (which is likely to be much more about defending decisions). English Nature wrote that "Chapter 3 provides a glowing picture...Our experience has been that this process [environmental appraisal] is not well entrenched in the policy development process across Government". English Nature went on to say that the DETR's appraisal of options for access to the countryside remains the only example of appraisal which they had seen that made a genuine attempt to set out the environmental effects against the costs of each option.[39]

33. The seven appraisals from four departments given as examples of published environmental appraisals are, with the exception of countryside access, assessments of the impacts of preferred options, or already announced decisions. For instance, Table 6.1 in the 1999 Pre-Budget Report only gives estimated environmental impact for the economic measure selected at the rate decided. Sometimes even this is not fully given. In the case of fuel duty the Treasury does not estimate the impact of a significant change of policy in the abandonment of the automatic escalator in favour of budget-by-budget decisions. As we noted in our report on the Pre-Budget Report 1999, when we compared the figures given in the 1999 Budget material with the latest Pre-Budget Report, carbon savings attributable to road fuel duty were being effectively halved under the new proposals. This reduction in impact was not set out.[40] Clearly the fact that Government only publishes material relevant to the successful policy option does not rule out the possibility that full appraisal was undertaken but it certainly does not allow us to audit that process.

(iii) Openness

34. As noted above the GMC report states that it is "for each department to decide the appropriateness of publishing these appraisals" but that "Green Ministers will encourage ...publication...wherever possible".[41] No clear criteria for when publication is 'possible' is given however, and, with the implicit exception of DfEE, no reference to a presumption for or against publication is in any individual department's approach.

35. We found this formulation to be excessively timid and can see no reason why Green Ministers could not agree a protocol for openness and transparency with regard to environmental appraisal of policy. Setting out departments' requirements for staff to follow longstanding guidance on environmental appraisal and incorporate results in advice to Ministers, itself not publicly available, does not create the opportunity to provide independent assurance over departments' performance in this regard and how they have taken the results into account in their policy decisions. Green Ministers should, as a first step, agree to follow the lead of the DfEE and include in policy documentation either confirmation that screening found no significant impacts or the appraisal of the policy being announced. This should be in addition to the certification of bills, in relation to their environmental impacts, which we have called for previously.[42] A further welcome step would be for Ministers to agree to publish, as a matter of course, full environmental policy appraisals including assessments of the impact of competing options.

36. At the very least Green Ministers must provide transparency in publishing a full list of policies where environmental appraisals have been undertaken by departments, whether fully published or not. Green Ministers could add value to this by including an assessment of what decisions were affected, and how, by the conduct of environmental appraisals.

37. We note the Green Ministers Committee's restatement of its commitment to undertake a review of the Cabinet Office requirement to set out significant costs and benefits of environmental impacts in Cabinet papers, and reiterate our call for this review, which should now be concluded, to be published.

(iv) Progress on policy appraisal and the environment

38. According to the Green Ministers' report some departments are clearly failing both the letter and the spirit of the commitment on environmental policy appraisal, for example, the Department of Health, the Home Office and the Cabinet Office. The Department of Health is still 'considering' how to take forward the 'Policy Appraisal and the Environment' guidance despite its original production nearly eight years ago and re-statement, in a very user-friendly form, nearly two years ago. The Home Office is still at the stage of 'giving consideration' to a requirement to include significant environmental costs and benefits in submissions in the light of an analogous and long-standing requirement in respect of Cabinet papers. And, while we were happy that the Cabinet Office is looking at cross-departmental systems we could see no reference to that office's own arrangements. On the other hand we regard the use by the Department of Social Security of internal audit to check compliance with its approach as a welcome move and an example for others to follow.[43] We were unimpressed with the overall Greening Government indicator given in the Quality of Life Counts document where the objective is stated as "integrating the environment into each department's policies and operations" but the only indicator given is operational (the now to be abandoned 'monergy' target for energy efficiency on the Government estate).[44] This is inadequate and a meaningful performance indicator for the conduct and impact of environmental appraisal of policy needs to be developed to address this deficiency.

33 GG II, recs (k) to (r) and HC 92 (1998-99) rec (g.) Back

34 GMCR, p20. Back

35 GG II, rec (m). Back

36 Op. cit., paragraph 3.5 (emphasis added). Back

37 GMCR, 'Key Achievements and Plans of Green Ministers' (after p30). Back

38 Paragraph 2 Back

39 Appendix 3. Back

40 HC 76 (1999-2000), rec (x). Back

41 GMCR, p19. Back

42 GG II, rec (o) . Back